Easing of the exit tax: relief after 2 years (5 years above €2.57m) instead of 15 years

Article 112 of the 2019 Finance Act amends Article 167 bis of the General Tax Code, which taxes unrealised gains on securities when the tax residence is transferred abroad. The deferred tax is cancelled when the securities are held for two years after departure (instead of fifteen), extended to five years when the total value of the securities exceeds €2.57m. Automatic deferral of payment is limited to departures to an EU state or a state with a tax recovery assistance agreement. Applicable to transfers of residence from 1 January 2019.