FB 2013: Exit taxes - an infringement deferred?

The government has at last acknowledged the need to react to EU developments on exit taxes. The proposals published in December offer taxpayers a choice between immediate payment and two alternative deferred payment plans (which permit deferral for up to ten years), with interest payable on the amounts deferred. These proposals, most notably the absence of a right to defer payment until actual realisation of the relevant gain, are unlikely to be seen as going far enough to ensure compliance with EU law.