Samuel Fernandes de Almeida (Partner) and Rita Pereira de Abreu (Associate) have written an article for the International Tax Review entitled "Analysis of the interaction of the Portuguese tax regime with the application of exit taxation of capital gains", in which they develop this aspect, as well as the issue of double taxation and the interaction.

“In some states, exit taxes are levied on accrued and (non-realised) capital gains upon the transfer of residency to another country. In the EU, EC law prevents immediate taxation on unrealised gains, requiring pursuant to settled case law of the ECJ that taxation is deferred to the moment of the sale, whilst preserving its taxing rights through different mechanisms.”

Read the article here.