Exit taxation - Is the new payment by installments concept contrary to European law?

German exit taxation was fundamentally revised as part of the introduction of the ATAD-UmsG. The previously applicable unlimited tax deferral for departures of EU/EEA citizens to an EU/EEA state was abolished. Instead, there is now a uniform installment payment concept, which is to be applied for departures to the EU/EEA as well as to third countries. In his article, Tobias Deschenhalm explains why this new regulation may violate European law.