35Finally, as to the possible relevance of the Court’s case-law on Council Directive 90/435/EEC of 23 July 1990 on the common system of taxation applicable in the case of parent companies and subsidiaries of different Member States ( OJ 1990 L 225, p. 6 ), it suffices to note that, as the Advocate General observes in points 45 to 49 of her Opinion, there is nothing in the judgments in Case C-294/99 Athinaiki Zithopiia [2001] ECR I-6797 and Case C-284/06 Burda [2008] ECR I-4571 that could be of assistance in the interpretation of Article 1(1) of Directive 2003/49 in relation to national legislation such as that at issue in the main proceedings. In those cases, it was the distribution of profits by a subsidiary to its parent company that was the event that gave rise to the tax in question. By contrast, the payments of interest at issue in the main proceedings do not constitute chargeable events for tax. The provisions of national law at issue in the main proceedings concern only the deductibility of such payments as expenditure for the purpose of calculating the basis of assessment of business tax.
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