The exit tax doesn't apply to "gains", it applies to the "value of your company" which is calculated in a way that often means you will owe thousands or even millions in money you don't have, and at no time had.

Yes - the value of your company is the gain. It is the money you would have if you sold the whole thing.

It's only a gain if you sell.

Selling a company and paying tax on the profit in tax is a completely different proposition from paying tax on hypothetical profit you haven't made (and might never make) just because you want to move.

Sounds indeed pretty terrible…