27As regards comparability of the situations, it must be pointed out that, in principle, permanent establishments situated in a Member State other than the Member State concerned are not in a situation comparable to that of resident permanent establishments in relation to measures laid down by that Member State in order to prevent or mitigate the double taxation of a resident company’s profits (judgment in Nordea Bank Danmark, C‑48/13, EU:C:2014:2087, paragraph 24).
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