Exit Taxes on Various Types of Corporate Reorganizations in Light of EU Law

This article studies the impact of exit taxation on cross-border corporate reorganizations, imposed by states to safeguard their tax base, in light of recent EU case law. The focus is on the balance between the Internal Market project and the legitimate interests of Member States in regard to taxation of latent capital gains and reserves that accrued while a certain territorial link was maintained with one or more Member States for some period in time.