44In that regard, it must be stated that the objective of an agreement on double taxation, such as the German-Swiss Agreement, is to prevent the same income from being taxed in each of the two parties to that agreement; it is not to ensure that the tax to which the taxpayer is subject in one State is no higher than that to which he or she would be subject in the other contracting State (judgment in Gilly, C‑336/96, EU:C:1998:221, paragraph 46).
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