Exit taxation and ECJ case law

European Court of Justice case law puts increasing pressure on the income tax systems of Member States. German exit taxation, for example, probably infringes EC law. Amendments to the exit taxation regime will, however, likely lead to economic distortions or encourage corporate tax planning. Therefore, comprehensive European solutions should be considered to resolve fundamental problems arising out of EC law requirements, such as the Commission's proposal on a common tax base for European groups or worldwide residence taxation.