23To that end, it is not unreasonable for the Member States to use the criteria followed in international tax practice (see, to that effect, judgments of 12 May 1998, Gilly, C‑336/96, EU:C:1998:221, paragraph 31, and of 16 July 2009, Damseaux, C‑128/08, EU:C:2009:471, paragraph 30 and the case-law cited).
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