31However, by applying tax reductions on a base that includes both non-exempt income from Belgium and exempt foreign income, and by deducting from the tax the share representing the latter in the total amount of income forming the taxable base only subsequently, Belgian tax legislation is liable, as the Belgian Government itself acknowledged in its written observations, to make taxpayers, such as the applicants in the main proceedings, lose part of the tax advantages that would have been granted to them in full had all of their income come from Belgium and if the tax reductions had thus been applied only to that income, or had the 2008 Circular applied to the tax advantages at issue.
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