26In so far as Article 65(1)(a) TFEU is a derogation from the freedom of movement of capital, it must be interpreted strictly. It cannot therefore be interpreted as meaning that all tax legislation which draws a distinction between taxpayers based on their place of residence or the State in which they invest their capital is automatically compatible with the Treaty (see judgment in Emerging Markets Series of DFA Investment Trust Company, C‑190/12, EU:C:2014:249, paragraph 55 and the case-law cited).
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