40However, the advantage which X BV claims in the present case may not be confused with the advantage provided by consolidation within a single tax entity. The main proceedings concern the possibility of deducting interest charges, not the general offsetting of costs and gains specific to a single tax entity. Far from reserving that possibility of deducting interest to single tax entities, Netherlands law affords that possibility to any company and restricts it only in the particular case and conditions laid down in Article 10a(2)(b) of the Law on corporation tax. In avoiding that restriction, a parent company which together with its subsidiary forms a single tax entity does not, therefore, obtain an advantage specifically linked to the tax scheme of the single tax entity.
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