TITJUR Opinion of Advocate General Kokott delivered on 19 July 2012. # Proceedings brought by A Oy. # Reference for a preliminary ruling: Korkein hallinto-oikeus - Finland. # Freedom of establishment - Article 49 TFEU - Tax legislation - Merger of a parent company established in one Member State with a subsidiary established in another Member State - Deductibility by the parent company of the subsidiary’s losses arising from its activity - Exclusion for non-resident subsidiaries. # Case C-123/11.