197 Second, as was observed in paragraph 83 above, the fact that the Špeciálny súd v Pezinku held that the letters of 15 January and 6 July 2004 had no binding effect and, accordingly, that they constituted mere recommendations, cannot prevent the Commission from finding in the present case that, in those two letters, reference was made to the Slovak Tax Directorate’s opposition not only to the applicant’s proposed arrangement, but also to any tax remission in the Slovak Republic.
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