27Although a convention for the avoidance of double taxation, such as that concluded with the Kingdom of the Netherlands, does not enable the tax levied in the Kingdom of Spain to be offset, since the Kingdom of the Netherlands has put in place an exemption scheme for dividends, that results from the exercise in parallel by two Member States of their fiscal sovereignty. In accordance with the case-law of the Court, the adverse consequences arising from the disparities between the rules of the Member States cannot be criticised for that reason by the law of the European Union (Case C-513/04 Kerckhaert and Morres [2006] ECR I-10967, paragraph 20, and Case C-298/05 Columbus Container Services [2007] ECR I-10451, paragraph 43).
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