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By Sami Douénias, partner and Ilaria Palieri, manager, PwC Luxembourg
Over the past few years, the Court of Justice of the European Union (“CJEU”) has addressed the question of exit taxation several times: first with individuals, in cases such as De Lasteyrie du Saillant and N and then with companies, with the recent highly publicised National Grid Indus (hereafter “NGI”)(1) case, not to mention the equally famous Daily Mail and Cartesio cases.
In the current economic climate, exit tax is clearly a very sensitive topic for many countries and for EU Member States in particular. Exit tax represents one of the tools that Member States can use to tax the profits accrued on their own territory (even unrealised profits) at the time a company migrates to...
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