Wächtler. Reference for a preliminary ruling. Free movement of persons. Switzerland. Exit tax. Finanzgericht Baden-Württemberg

Request for a preliminary ruling from the Finanzgericht Baden-Württemberg in the case Wächtler.

Are the provisions of the Agreement of 21 June 1999 between the European Community and its Member States, of the one part, and the Swiss Confederation, of the other, on the free movement of persons, which entered into force on 1 June 2002, and in particular the preamble and Articles 1, 2, 4, 6, 7, 16 and 21 thereof and Article 9 of Annex I thereto, to be interpreted as precluding rules of a Member State under which, in order to prevent any element of the taxable basis from being lost, latent, as yet unrealised, appreciations in the value of company rights (without deferment) are charged to tax in the case where a national of that Member State with initially unlimited tax liability transfers his residence from that State to Switzerland and not to a Member State of the European Union or to a State to which the European Economic Area Agreement applies?

C-581/17

 

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