39First, the Court must assess whether such a difference in treatment may be justified by the need to safeguard the allocation of the power to impose taxes between the Member States. The Court has held, in the judgment of 25 February 2010, X Holding (C‑337/08, EU:C:2010:89), as is apparent from paragraph 23 of the present judgment, that consolidation at the parent-company level for the profits and losses of the companies constituting a single tax entity represents an advantage which may justifiably be reserved to resident companies in view of the need to safeguard the allocation of the power to impose taxes between the Member States.
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