Judgment_paragraph 51 · European Commission v Republic of Estonia (C-39/10)

51There could be discrimination within the meaning of the Treaty between residents and non-residents only if, notwithstanding their residence in different Member States, it were established that, having regard to the purpose and content of the national provisions in question, the two categories of taxpayers are in a comparable situation (see Gschwind, paragraph 26).

European Commission v Republic of Estonia (C-39/10)

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