22In relation to direct taxation, residents and non-residents are generally not in comparable situations because the income received in the territory of a Member State by a non-resident is in most cases only a part of his total income, which is concentrated at his place of residence, and because a non-resident’s personal ability to pay tax, determined by reference to his aggregate income and his personal and family circumstances, is easier to assess at the place where his personal and financial interests are centred, which in general is the place where he has his usual abode (see, inter alia, judgments in Schumacker, C‑279/93, EU:C:1995:31, paragraphs 31 and 32, and Grünewald, C‑559/13, EU:C:2015:109, paragraph 25).
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