41As a preliminary point, it should be noted that compliance with Article 56 TFEU is binding on Member States even in the context of the adoption of legislation such as the 2017 tax regime, despite the fact that that regime relates to direct taxes. According to settled case-law, whilst direct taxation falls within their competence, the Member States must nonetheless exercise that competence consistently with EU law (judgment of 23 January 2014, Commission v Belgium, C‑296/12, EU:C:2014:24, paragraph 27 and the case-law cited).
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