24However, the allocation of powers of taxation mentioned in paragraph 22 of this judgment does not allow Member States to apply measures contrary to the freedoms of movement guaranteed by the FEU Treaty. As far as concerns the exercise of the power of taxation so allocated by bilateral conventions for the avoidance of double taxation, the Member States must comply with EU rules and, more particularly, observe the principle of equal treatment (judgments of 12 December 2002, de Groot, C‑385/00, EU:C:2002:750, paragraph 94, and of 12 December 2013, Imfeld and Garcet, C‑303/12, EU:C:2013:822, paragraph 42 and the case-law cited).
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