Domestic law does not include exit taxes as such.
The winding up of a company or branch, upon which the reimbursement of capital and the distribution of remaining assets is performed, will trigger the following consequences:
- The repayment of the capital invested does not constitute taxable income.
- Any distribution of remaining assets in excess of the capital invested qualifies as dividend and therefore is taxed under the special rules applicable to such type of income.
[NOTE: business restructuring in the sense of re-arranging the supply chain and the associated functions and risks is addressed under Transfer pricing below]