10Second, as regards the profits from shareholdings in a company established in another Member State which fulfils the conditions laid down in Council Directive 90/435/EEC of 23 July 1990 on the common system of taxation applicable in the case of parent companies and subsidiaries of different Member States (OJ 1990 L 225, p. 6), as amended by Council Directive 2006/98/EC of 20 November 2006 (OJ 2006 L 363, p. 129), the deduction may be made, in accordance with the second limb of the first sentence of Paragraph 9(7) of the GewStG 2002 where the shareholding corresponds to at least one tenth of the share capital at the beginning of the reference period.
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