A ministerial ruling (EAS 2741) has been critically analysed by Michael Lang in SWI 2006, 556. Two objections actually have merits; this is, however, not true with regard to the argument that in the case of a transfer of residence from Austria to Switzerland the increase in value of a participation in a Swiss corporation cannot be taxed in Austria. The treaty does not inhibit a determination of the taxable increase in value and of a mere calculation of the tax at the time of departure. The treaty only disallows charging such a tax on the occasion of the transfer of residence; a postponement of the Austrian exit taxation until the moment of sale of the participation is in line with the treaty.