Where are wealth holders moving to?

Please note: Barclays does not offer tax advice. Professional advice sought always be sought. All figures quoted below were correct at the time of publishing but may be subject to change.

The UK’s decision to abolish the ‘resident non-domiciled’ (RND) tax regime has sharpened the minds of many international wealth holders. Until recently, there were estimated to be over 60,000 so-called ‘non-doms’ in the UK¹.

At a time when wealth holders are more peripatetic than ever, the option to pack up and move – whether from the UK or another base – is increasingly realistic. Even more so as different jurisdictions compete to incentivise relocations to their own countries. 

According to recent research, nearly 130,000 millionaires around the world are expected to migrate in 2024, with tax cited as a key catalyst. This trend would break the previous record of 120,000 set in 2023².

In the following article, we share insights about some of the most popular relocation hubs for ultra-high-net-worth (UHNW) individuals and their families.

As a reminder, Barclays does not offer tax advice. The jurisdictions covered below are a cross section, and this is not an exhaustive list. They have been chosen based on our team’s insights, and/or location.  

Monaco

As evidence of its ongoing ability to attract UHNW individuals, Monaco recently topped the rankings for how much money a resident needs – a cool $12,883,000 – in order to be considered part of the 1% club (apropos individual net wealth). It pipped Luxembourg into second place ($10.8m), followed by Switzerland ($8.5m)³. 

The Principality benefits from a great year-round climate, close proximity to major European cities, and a much sought-after quality of life. 

From a tax perspective, there is currently no personal income tax for individuals (except for people of French nationality who decide to move their residence to Monaco). Consequently, any individual resident in the Principality may receive income from a professional activity, dividends, and/or capital gains in exemption from any tax or taxes levied in the Principality of Monaco. 

However, for any income from a foreign source, it is necessary to validate the taxation in the country of origin related to income, or the withholding tax to which it may possibly be subject, in the international tax framework. 

Regarding visas, it can take 5-6 months to receive a resident permit. As you’d expect, certain criteria must be met including, but not limited to, securing accommodation and not having a criminal record.

For more information about property in the Principality, read ‘The future of real estate in Monaco’. 

Switzerland 

With a reputation for stability, security, and stunning scenery, Switzerland is another popular European hub with the super rich.

From a property perspective, the country remains a prime hotspot but there are buying restrictions worth being aware of.  They can determine where exactly a foreigner can buy, and often limit them to tourist zones such as ski resorts. 

(For any skiers reading this, you might like to see, ‘Swiss ski resorts remain in high demand’). 

With regards to tax, and at a federal level, there are currently no net wealth, real estate, inheritance or gift taxes. The total tax burden on income is limited to 11.5%. 

However, it is worth noting that the Swiss cantons – the name given to the country’s 26 districts –have fiscal sovereignty and taxation rights. Depending on the canton, the combined income tax rate (federal and cantonal) could be as low as 22%. Income tax on dividends from substantial participations (more than 10%) can be reduced by up to 50%. The transfer of assets to one’s own children, grandchildren and spouses is exempt from gift and inheritance tax in most of the cantons. 

Expenditure-based (lump sum) taxation is available to Swiss resident foreign individuals without gainful employment in Switzerland. This tax regime is only applicable to non-Swiss persons who make Switzerland their tax home for the first time or after at least ten years outside of the country. 

The United Arab Emirates

The UAE is estimated to be home to 202,000 millionaires⁴, is forecast to attract a net inflow of 6,700 global millionaires and by the end of 2024⁵.

Residents are not liable for income or wealth taxes, making it one of the world’s most tax-efficient destinations.

Part of the appeal for global business owners who relocate there is the strategic location between Asian, European and African markets.

Broadly speaking, Expats benefit from the absence of personal income taxes, and for many years, the UAE levied virtually no taxes of any kind. However, since 2017, various business taxes have been introduced, albeit at relatively low rates. 

These low rates, and the absence of withholding tax or restrictions on the movement of funds, are partly designed to attract foreign businesses. And for those businesses that do make the move, the two most common taxes they will encounter are corporate tax and value added tax. However, importers may also be required to pay customs duties.

Overall, the UAE is considered to be a convenient and tax-efficient hub for UHNW individuals and their families. While some visitors are attracted by the year-round warmth, the heat can be extreme at times, and is worth factoring into any relocation decisions. 

Italy 

For a while now, Italy has been strategically positioning itself as an alternative UHNW relocation spot to long-standing favourites like Monaco and Switzerland. And tax incentives have played a big part of that strategy.

Subject to certain criteria being met, eligible foreign nationals can leverage a yearly flat tax of €200,000 on foreign source income in lieu of progressive tax rates (currently 46%) i.e. income from foreign investments, foreign financial assets and any other income deriving from foreign assets or foreign activities. It is important to note that for the first five years of Italian tax residency, specific rules apply to certain capital gains realised. 

Eligibility is determined by whether an individual can (i) transfer their tax residence to Italy, and (ii) evidence that they have not been Italian tax residents for at least nine of the previous 10 tax periods. 

The special regime is revocable and lasts up to 15 years, after which it cannot be renewed. It can also be extended to family members who move their tax residence to Italy by paying €25,000 per year for each family member.

In parallel with this, the country offers exemption from wealth taxes on foreign real estates and financial assets. It also exempts qualifying wealth holders from inheritance and gift taxes on all assets held abroad. 
 
The ‘Investor Visa’ is one way that UHNW individuals can secure their residency. It relies on a substantial investment being made in any of the following forms: 

• €2million in government bonds
• €250,000 in an innovative start up in Italy
• €500,000 in an existing Italian company
• €1million in a philanthropic donation 

The Investor Visa grants the holder the possibility to apply for a special Residence Permit in Italy, valid for an initial period of two years and renewable before its expiry date.

There is also something known as an ‘Elective Residence Visa’, which allows non-EU nationals to reside in Italy for an open long-tern visit without the need for an employment.

The UK

While the scrapping of the RND regime will invariably see more tax being paid by international UHNW individuals in the UK, it’s important to state that the UK remains a popular destination. It continues to attract new residents, and to retain existing ones.

Broadly speaking, its appeal lies in the long-held perception of safety and cultural tolerance, as well as a supportive business culture, and world-class educational establishments – both at a school and university level. 

At the time of writing, the new tax regime that replaces the RND regime, will see (relevant) newcomers being given a 4-year tax free window on their offshore assets, which they will also be permitted to bring into the UK tax free. This requires them to have been resident outside the UK for ten consecutive years beforehand. 

For res non-dom individuals who have already been here for longer than four years (as of the new tax year starting in April 2025), the exception won’t apply.  They will also find themselves liable for tax on their worldwide income and gains. After ten years of UK residence, their worldwide assets are proposed to be in scope of UK inheritance tax. Depending on the level of wealth involved, this may be a big adjustment for some wealth holders, requiring very careful planning. Legislation is expected to be released with the Budget on 30th October.

By the close of 2024, Britain is expected to have seen a net loss just-shy of 10,000 high-net-worth individuals⁶. It remains to be seen how big, or how little, a role the RND abolition has played in that trend. 

Final words

When it comes to financial planning, tax shouldn’t be the sole catalyst for relocation. An international move requires many more things to be taken into account, from general lifestyle to schools, and more. 

Tax considerations are undeniably an important part of financial planning, but they are also subject to change. This is another reason why major life decisions should be taken against a range of factors, and not just with tax in mind.

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