25It should be noted that such legislation, which makes the application of a tax-free allowance in respect of the immovable property concerned dependent on the place of residence of the deceased and the heir at the time of the death, leads to succession between non-residents including such property being subject to a higher tax liability than that involving at least one resident and therefore has the effect of reducing the value of that succession (see, by analogy, Eckelkamp and Others, paragraphs 45 and 46; Mattner, paragraphs 27 and 28; and Missionswerk Werner Heukelbach, paragraph 24).
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