45In the present case, it should be noted that the difference in treatment that Mr Bukovansky claims to have suffered results from the allocation of fiscal sovereignty between the parties to the agreement concerned and follows from the disparities existing between the tax schemes of those parties. However, as noted in paragraphs 37 and 38 of the present judgment, the choice by those parties, with a view to allocating fiscal sovereignty between them, of different connecting factors is not such as to constitute prohibited discrimination.
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