59On this point, it should be recalled that the Court has indeed held that the need to preserve the coherence of a tax system may justify a restriction on the exercise of the fundamental freedoms guaranteed by the Treaty. However, for such a justification to be accepted, a direct link has to be established between the granting of the tax advantage concerned and the offsetting of that advantage by a particular tax (see Manninen, paragraph 42, and Case C-182/08 Glaxo Wellcome [2009] ECR I-8591, paragraphs 77 and 78).
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