31That interpretation is in no way weakened by the Belgian Government's observation that the minimum tax bases provided for in the national legislation at issue in the main proceedings are often more favourable to non-resident taxpayers than the comparison-based taxation applied to resident taxpayers. Even on the assumption that the Belgian tax system is more often favourable to non-resident taxpayers, the fact remains that where that system proves disadvantageous for non-resident taxpayers, it results in unequal treatment by comparison with resident taxpayers and thus creates a hindrance to the freedom of establishment guaranteed by Article 52 of the Treaty (see, by analogy, Case C-141/99 AMID [2000] ECR I-11619, paragraph 27 and the case-law cited).
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