[gndk]

Because nobody has sued the German tax office and taken it up to the EU courts yet. From my understanding and anecdotes from my tax advisor, most of these cases get settled by the tax office before going to court to avoid creating a precedent.

The tax office just lost a case at the highest German court against an entrepreneur who moved to Switzerland, which will force them to accept an unlimited interest-free deferral in most cases. See https://winheller.com/blog/keine-sofortige-wegzugsbesteuerun... (in German)

[hnhg]

Unfortunately, so far that deferral will most likely come with the requirement for a security, typically cash. That is the prevailing view of tax specialists right now, but will depend on each individual's experience with their local tax authorities.