21It is true that, as the Court has previously held and the Spanish Government has pointed out, the situations of residents and of nonresidents in a given State are not generally comparable as far as direct taxes are concerned, since income received in the territory of a State by a nonresident is in most cases only a part of his total income, which is concentrated at his place of residence, and a nonresident's personal ability to pay tax, determined by reference to his aggregate income and his personal and family circumstances, is more easy to assess at the place where his personal and financial interests are centred, which in general is the place where he has his usual abode (Case C-279/93 Finanzamt Köln-Altstadt v Schumacher [1995] ECR I-225, paragraphs 31 and 32, and Case C-391/97 Gschwind v Finanzamt Aachen-Außenstadt [1999] ECR I-5451, paragraph 22).
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