12The Commission submits that, even though the rate of taxation applicable to the income of non-resident financial institutions is lower than that levied on the similar income of resident financial institutions, the tax burden borne by the former in Portugal is, in fact, significantly higher, since, unlike resident legal entities, non-resident legal entities cannot deduct from the amount of taxed income the operating costs directly connected with the activity pursued. As is apparent from Case C-443/06 Hollmann [2007] ECR I-8491, paragraphs 35 to 38, such a difference in treatment amounts to discrimination against non-resident financial institutions.
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