German exit tax when moving to Switzerland – The new “Wächtler” decision of the BFH

In its decision dated September 6, 2023 (I R 35/20), published on January 11, 2024, the First Senate of the German Federal Fiscal Court (BFH) dealt with the German exit taxation pursuant to Section 6 German Foreign Tax Act (AStG) in connection with relocations to Switzerland. In its decision the BFH comments on the much-discussed "Wächtler" decision of the European Court of Justice (ECJ).