Judgment_paragraph 24 · European Commission v United Kingdom of Great Britain and Northern Ireland (C-172/13)

24However, according to the case-law of the Court, such a difference in treatment may be justified by three overriding reasons in the public interest, taken together, that is to say, by the need to preserve the balanced allocation of powers of taxation between the Member States, the need to prevent the double use of losses and the need to combat tax avoidance (see, to that effect, judgments in Marks & Spencer, EU:C:2005:763, paragraph 51; Oy AA, C‑231/05, EU:C:2007:439, paragraph 51; and A, C‑123/11, EU:C:2013:84, paragraph 46).