32It must be held that to permit the branches of non-resident companies to transfer their profits in the form of unusual or gratuitous advantages to their parent companies may well undermine the balanced allocation of the power to tax between Member States. It would be liable to undermine the very system of the allocation of the power to tax between Member States because the Member State of the branch granting unusual or gratuitous advantages would be forced to renounce its right, in its capacity as the State of residence of that permanent establishment, to tax the branch’s income in favour, possibly, of the Member State in which the recipient parent company has its registered office (see, to that effect, judgment of 21 January 2010, SGI, C‑311/08, EU:C:2010:26, paragraph 63).
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