55According to settled case-law, a distinction must be made between the differences in treatment authorised by Article 65(1)(a) TFEU and discrimination prohibited by Article 65(3) TFEU. For national tax legislation such as the legislation at issue to be capable of being regarded as compatible with the provisions of the FEU Treaty on the free movement of capital, it is necessary that the difference in treatment should concern situations which are not objectively comparable or be justified by an overriding reason in the public interest (see, to that effect, judgments of 3 September 2014, Commission v Spain, C‑127/12, not published, EU:C:2014:2130, paragraph 73; of 11 September 2014, Verest and Gerards, C‑489/13, EU:C:2014:2210, paragraph 28; and of 17 September 2015, Miljoen and Others, C‑10/14, C‑14/14 and C‑17/14, EU:C:2015:608, paragraph 64).
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