31It must be noted, moreover, that the finding made in paragraph 25 above is not called into question by the principle of fiscal neutrality. As the Advocate General stated at point 28 of her Opinion, that principle cannot extend the scope of an exemption in the absence of clear wording to that effect. That principle is not a rule of primary law which can determine the validity of an exemption, but a principle of interpretation, to be applied concurrently with the principle of strict interpretation of exemptions (see, to that effect, judgment in Deutsche Bank, C‑44/11, EU:C:2012:484, paragraph 45).
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