Judgment of the Court (First Chamber) of 11 May 2023.#Ministre de l’Économie, des Finances et de la Relance v Manitou BF SA and Bricolage Investissement France SA.#Requests for a preliminary ruling from the Conseil d'État.#References for a preliminary ruling – Taxation – Article 49 TFEU – Freedom of establishment – Corporation tax – Group taxation (French ‘intégration fiscale’) – Tax exemption for dividends paid by subsidiaries belonging to the tax-integrated group – Resident parent company – Capital links with resident and non-resident companies without forming a tax-integrated group – Tax exemption of dividends paid by non-resident subsidiaries – Non-deductible costs and expenses relating to the holding – Lack of neutralisation as regards the add-back of those costs and expenses.#Joined Cases C-407/22 and C-408/22.