44Consequently, if taxation at a rate of less than 10% was not practised under the Netherlands tax regime, the unavoidable and not uncertain consequence (see, a contrario, judgment of 3 March 2020, Tesco-Global Áruházak, C‑323/18, EU:C:2020:140, paragraph 72) of a condition such as that laid down in Article 10a(3)(b) of the Law on Corporation Tax is that it affects only cross-border situations.