38In fact, as the Advocate General stated in points 57 to 63 of her Opinion, it cannot be excluded from the outset that a third party may take into account for tax purposes the losses of the subsidiary in that subsidiary’s State of establishment, for example following a sale of that subsidiary for a price including the tax advantage represented by the deductibility of losses for the future (see, to that effect, judgment of 21 February 2013, A, C‑123/11, EU:C:2013:84, paragraph 52 et seq., and judgment delivered today, Memira Holding, C‑607/17, paragraph 26).
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