98However, that difficulty cannot justify a categorical refusal to grant a tax benefit in respect of investments made by investors from that Member State. When the holding companies incorporated under Luxembourg law apply for exemption from the disputed tax, the French tax authorities may request those companies themselves to provide the evidence which they consider they need to be fully satisfied as to the transparency of those companies' rights of ownership and the structure of their shareholdings, irrespective of whether there is a convention on administrative assistance or a treaty containing a clause which prohibits discrimination in matters of taxation.
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