50In the first place, it should be recalled that the balanced allocation of the power to impose taxes between the Member States, which has been invoked by all the Governments which have submitted observations and by the Commission, is a legitimate objective recognised by the Court (see, inter alia, Case C-371/10 National Grid Indus [2011] ECR I-12273, paragraph 45; and Case C‑18/11 Philips Electronics UK [2012] ECR, paragraph 23), which may make it necessary to apply to the economic activities of taxpayers established in one of those Member States only the tax rules of that State in respect of both profits and losses (see, to that effect, Marks & Spencer, paragraph 45; Oy AA, paragraph 54; and Lidl Belgium, paragraph 31).
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