European Union – Freedom of movement. The provisions of the Agreement between the European Community and its Member States and the Swiss Confederation on the free movement of persons should be interpreted as precluding a tax regime of a member state which, in a situation where a natural person who was a national of a member state and who pursued an economic activity in the territory of the Swiss Confederation transferred his domicile from the member state whose tax regime was at issue to Switzerland, provided for the collection, at the time of that transfer, of the tax payable on unrealised capital gains with respect to shares owned by that national, whereas, if domicile was retained in that member state, the collection of the tax took place only at the time when the capital gains were realised, namely, on a disposal of the shares concerned. The Court of Justice of the European Union so held in a preliminary ruling in proceedings between the applicant and the German tax authority.