The German exit tax over time - from an exotic to a mass phenomenon?

Since 1972, the tax legislator has drastically expanded the scope of the German exit tax in several steps. This special form of income taxation when moving abroad therefore affects a substantially larger group of people today than when it was introduced in 1972. For EU citizens moving within the EU, the German exit tax was still bearable until the end of 2021 due to the previous generous deferral rules. With the new regulation as of January 1, 2022, the legislator has combined a significantly expanded scope of application of the exit tax with drastically restricted deferral rules at the same time. As a result, many affected taxpayers will go to the fiscal courts. It is to be expected that case law will once again intervene to correct the German exit taxation.