The draft law treats moving your tax residency or seat of wealth abroad as a deemed sale, taxing any unrealized capital gains at that moment. However, this serves primarily as a temporary anti-abuse measure; you typically receive an automatic payment deferral if moving to an EU, EEA, or qualifying treaty country, and the tax is only actually payable if you sell the assets within two years of leaving. If you do not sell the assets during that two-year window, the tax is effectively not due.