Exit Taxation of Individuals vs. the Free Movement of Persons - Examination by means of the German exit tax provision for individuals § 6 AStG and the CJEU’s case law
While an exit tax regime satisfies principles like fiscal sovereignty, fiscal territoriality, source and benefit as well as it can find justification in them at a national level, other conflicting issues arise. For instance, from the perspective of an individual, this can lead to double taxation when the Host State does not accept a step-up or deduction for the value on which taxes have already be
