Abstract

The article at hand encompasses an outline of the model concept of the exit tax (tax on unrealized gains) formed in the European Union law and the analysis of Polish regulations in this regard, which came into force on January 1, 2019 with respect to their compliance with the model, European solutions. The article contains four five sub-chapters. In the first one, the author briefly introduces the concept of the exit tax and its development, in the second, he presents the European Court of Justice jurisprudence concerning exit tax, which preceded the enactment of Directive 1164 from 2016, in the third he describes the exit tax regulations enshrined in Directive 1164, in the fourth - which constitutes the fulcrum of the whole article – he analyses Polish exit tax provisions in the light of model concept presented in the European Union law with the particular emphasis on the discrepancies between these two, and in the fifth he summarizes the conclusions.