English to Romanian Bus/Financial Law: Taxation & Customs

The company exit taxes in case of the migration of companies is another ongoing issue as well as the tax exit rules on individuals which are designed to prevent tax avoidance by moving abroad.
In particular, the view that this provision covers all forms of "exit tax" is far from unanimously accepted. Some authors consider that exit taxation constitutes a form of purely domestic taxation, outside the scope of the tax treaties. Other commentators, take the opposite view that this form of taxation is covered by tax treaties. Nevertheless, some of the latter invoke, as a relevant provision, not Article 13 of the OECD Model, but Article 21 (other incomes), owing to the fact that the capital gain subject to the exit tax is not yet realized.