The (in)freedom to move out of Germany: Innovations to the “exit tax” by the “AEAStG-E” of 20.07.2023

On July 20, 2021, the German Federal Ministry of Finance published the discussion draft on the principles for the application of the Foreign Tax Act. In the very comprehensive draft, comments were also made on the “exit tax” according to Section 6 AStG. There are some clarifications, some surprises, some profiscal views and ultimately also some open questions. In any case, the genesis of the final principles must be closely followed in order to be able to react if necessary.