15As the Court has held, in relation to direct taxes, the situations of residents and of nonresidents are generally not comparable, because the 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 because a nonresident's personal ability to pay tax, determined by reference to his aggregate income and his personal and family circumstances, is easier 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 (Schumacher, cited above, paragraphs 31 and 32; Case C-391/97 Gschwind [1999] ECR I-5461, paragraph 22; Case C-87/99 Zurstrassen [2000] ECR I-3337, paragraph 21, and Gerritse, cited above, paragraph 43).
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