25It must be recalled from the outset that, in accordance with settled case-law, although the Member States are at liberty, in the framework of bilateral agreements for the avoidance of double taxation, to determine the connecting factors for the purposes of allocating powers of taxation, that allocation of powers of taxation does not allow them to apply measures that are contrary to the freedoms of movement guaranteed by the Treaty. As far as concerns the exercise of the power of taxation thus allocated by bilateral conventions to prevent double taxation, the Member States must comply with EU rules (see, inter alia, judgments of 12 December 2002, de Groot, C‑385/00, EU:C:2002:750, paragraphs 93 and 94; of 12 December 2013, Imfeld and Garcet, C‑303/12, EU:C:2013:822, paragraphs 41 and 42; and of 22 June 2017, Bechtel, C‑20/16, EU:C:2017:488, paragraph 66) and, more particularly, observe the principle of equal treatment (see, to that effect, judgment of 12 December 2002, de Groot, C‑385/00, EU:C:2002:750, paragraph 94).
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