The exit tax is the result of the Council Directive of the European Union of 12 July 2016, which counteracts tax avoidance practices through asset migration. The regulation most often concerns a situation in which a company uses tax reliefs in one of the Member States and, upon expiry of the preference period, transfers its registered office to another country.
As explained by Agata, the provisions of the EU Directive apply to CIT tax payers. However, it is not clearly indicated whether or not exit tax will also apply to personal income tax (PIT) payers who have changed tax residences.
Althought, in this situation, the introduction of exit tax does not constitute a violation of Community law, it is still controversial.
The whole article is available here (only in Polish).