46The Court has also held that a distinction must, therefore, be made between the differences in treatment authorised under article 58(1)(a) EC (now, after amendment, Article 65(1)(a) TFEU) and the discrimination prohibited by Article 58(3) EC (now, after amendment, Article 65(3) TFEU). Before national tax legislation can be regarded as compatible with the Treaty provisions on the free movement of capital, the difference in treatment resulting from that legislation must concern situations which are not objectively comparable or must be justified by an overriding reason in the public interest (see, to that effect, judgment of 29 April 2021, Veronsaajien oikeudenvalvontayksikkö (Income paid by UCITS), C‑480/19, EU:C:2021:334, paragraph 30 and the case-law cited).
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