21In those circumstances, suffice it to recall, as the Advocate General stated in point 22 of her Opinion, that it is clear from the case-law of the Court that the application of withholding tax, as a method of taxation, to non-resident service providers, when resident service providers are not subject to such tax, whilst constituting a restriction on the freedom to provide services, may be justified by overriding reasons in the general interest, such as the need to ensure the effective collection of tax (see, to that effect, judgments of 3 October 2006 in FKP Scorpio Konzertproduktionen, C‑290/04, EU:C:2006:630, paragraph 35, and 18 October 2012 in X, C‑498/10, EU:C:2012:635, paragraph 39).
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