97Since the chapter of the Treaty on freedom of establishment does not contain any provision which extends the application of its provisions to situations concerning the establishment of a company of a Member State in a third country or the establishment of a company of a third country in a Member State (see Holböck, paragraph 28; Case C-452/04 Fidium Finanz [2006] ECR I-9521, paragraph 25; Scheunemann, paragraph 33; the order in Case C-102/05 A and B [2007] ECR I-3871, paragraph 29; and the order in Test Claimants in the CFC and Dividend Group Litigation, paragraph 88), legislation relating to the tax treatment of dividends originating in third countries is not capable of falling within the scope of Article 49 TFEU.
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