74As regards, in the second place, the argument relating to the difference in the situation of resident and non-resident pension funds in terms of whether it is possible to take into account allocations to provisions for pension commitments as professional expenditure, it should be recalled that the Court has held that, in relation to expenditure, such as professional expenses directly linked to an activity that has generated taxable income in a Member State, residents and non-residents of that State are in a comparable situation (see, inter alia, judgments of 31 March 2011, Schröder, C‑450/09, EU:C:2011:198, paragraph 40, of 8 November 2012, Commission v Finland, C‑342/10, EU:C:2012:688, paragraph 37 and of 24 February 2015, Grünewald, C‑559/13, EU:C:2015:109, paragraph 29).
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