56Although the preservation of the allocation of the power to impose taxes between Member States is admittedly likely to constitute an overriding reason relating to the public interest justifying a restriction on the exercise of freedom of movement within the European Union, it should be stated that such a justification was however rejected by the Court in de Groot, which concerned rules similar to the contested rules. As the Advocate General noted at paragraph 51 of his Opinion, it is apparent from paragraphs 98 to 101 of that judgment that such a justification cannot be invoked by a taxpayer’s State of residence in order to evade its responsibility in principle to grant to the taxpayer the personal and family allowances to which he is entitled, unless, of their own accord or as a consequence of specific international agreements, the States in which one part of the income is received grant such allowances.
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