37Hearing requests for a preliminary ruling on the question of whether the agreements on double taxation concluded between the EU Member States must be compatible with the principle of equal treatment and, in general, with the freedoms of movement guaranteed by primary EU law, the Court has held that the Member States are free to determine the connecting factors for the allocation of fiscal sovereignty in bilateral agreements for the avoidance of double taxation, but are obliged, in exercising the power of taxation thus allocated, to observe that principle and those freedoms (see judgments in Gilly, C‑336/96, EU:C:1998:221, paragraph 30; Renneberg, C‑527/06, EU:C:2008:566, paragraphs 48 to 51; and Imfeld and Garcet, C‑303/12, EU:C:2013:822, paragraphs 41 and 42).
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