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Exit taxation violates free movement agreement

KPMG in the media: Heiko Kubaile

​Until recently, if an entrepreneur moved from Germany to Switzerland, any increase in the value of his shareholdings while resident in Germany was subject to exit taxation. According to the European Court of Justice, this violates the Agreement on the Free Movement of Persons between the EU and Switzerland. Heiko Kubaile and Paul Fischer welcome this ruling and make recommendations on how taxpayers should deal with pending cases.

Heiko Kubaile

Partner, Head of German Tax & Legal Center

KPMG Switzerland


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KPMG International Cooperative (“KPMG International”) is a Swiss entity.  Member firms of the KPMG network of independent firms are affiliated with KPMG International. KPMG International provides no client services. No member firm has any authority to obligate or bind KPMG International or any other member firm vis-à-vis third parties, nor does KPMG International have any such authority to obligate or bind any member firm.

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