121It has already been recognised that a restriction on the exercise of a freedom of movement within the European Union can be justified in order to safeguard the allocation of the power to impose taxes between the Member States (see, to this effect, Case C-446/03 Marks & Spencer [2005] ECR I-10837, paragraph 45; Case C-231/05 Oy AA [2007] ECR I-6373, paragraph 51; and Case C-414/06 Lidl Belgium [2008] ECR I-3601, paragraph 42). Such a justification, which constitutes an overriding reason in the public interest, can therefore, a fortiori, be recognised in the Member States’ relations with non-member States.
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