25It should be observed that, assuming that VTL comes within the field of direct taxation and assuming that CIBA’s liability to pay, on the one hand, VTL on the basis of a calculation which takes account of the wage costs in respect of its branch in the Czech Republic and, on the other, contributions relating to that Member State’s public policy on employment in respect of the workers employed in that branch may be considered to be double taxation, such a fiscal disadvantage results from the exercise in parallel by two Member States of their fiscal sovereignty (see, to that effect, Case C-513/04 Kerckhaert and Morres [2006] ECR I-10967, paragraph 20, and Case C-67/08 Block [2009] ECR I-883, paragraph 28).
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