58As regards the question of comparability, it must first be stated that in the context of a tax rule, such as that at issue in the main proceedings, which seeks to exempt from tax profits distributed by resident companies, the situation of a resident investment fund receiving profits is comparable to that of a non-resident investment fund receiving profits in so far as, in each case, the profits made are, in principle, liable to be subject to economic double taxation or a series of charges to tax (see, to that effect, Case C‑446/04 Test Claimants in the FII Group Litigation, paragraph 62; Haribo Lakritzen Hans Riegel and Österreichische Salinen, paragraph 113; Case C-284/09 Commission v Germany [2011] ECR I-9879, paragraph 56; and Santander Asset Management SGIIC and Others, paragraph 42 and case-law cited).
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