OPINION OF ADVOCATE GENERAL
WATHELET
delivered on 27 September 2018 (1)
Case C‑581/17
Martin Wächtler
v
Finanzamt Konstanz
(Request for a preliminary ruling from the Finanzgericht Baden-Württemberg (Finance Court, Baden-Württemberg, Germany))
(Reference for a preliminary ruling — Taxation — Agreement between the European Community and its Member States, of the one part, and the Swiss Confederation, of the other, on the free movement of persons — Transfer of domicile to Switzerland — Rules of a Member State under which, in such a case, unrealised capital gains on company shareholdings are to be taxed)