There are many reasons ultra high net worth (UHNW) individuals choose to relocate to a different country – from lifestyle, education, and security to business or investment opportunities, or tax benefits. In recent years, a small number of jurisdictions, including Italy and Portugal, have become common choices for internationally mobile UHNW individuals, including those leaving the UK. Their popularity has been boosted by generous immigration and tax rules for new residents, in addition to the desirability of the locations themselves. However, recent changes to some regimes mean different jurisdictions are becoming more popular choices, including the UAE.
Any proposed international relocation requires a great deal of planning. Anyone thinking about a move (UHNW individual or otherwise) should obtain advice at the earliest opportunity, ideally at least six to 12 months before their intended departure. When planning for a relocation, many of the things you need to consider fall under one of three headings – practicalities, immigration and tax.
The Channel Islands
For British nationals looking to become non-UK resident, the Channel Islands offer considerable advantages for high net worth (HNW) individuals. British nationals do not need a visa to live and work in Jersey or Guernsey, and the islands have a low tax regime for wealthy individuals.
Add a familiar legal system, political stability, proximity to, and excellent transport and communication links with, the UK and Europe and the appeal is obvious. The weather is generally better than in the UK mainland too!
While British nationals have the right to live or work in Jersey and Guernsey, housing laws in both jurisdictions potentially restrict their accommodation options. In Jersey, individuals accepted on the high value residency programme can, however, rent or buy any property. In Guernsey, properties on the 'Open Market Register' are available to individuals arriving from the UK (or other countries, subject to visa permissions). Both jurisdictions also offer beneficial tax regimes for residents which can limit the income tax payable on foreign-source income. In addition, capital gains are not subject to tax in either Jersey or Guernsey and neither has any gift, inheritance, estate or wealth tax.
It has been reported that a significant majority of the high net worth individuals moving to the Channel Islands in recent years have been British nationals; it is likely that this is going to be a continuing trend.
Greece
Greece remains in the top ten countries worldwide attracting wealthy foreigners. This is not surprising given the relaxed pace of life, almost year-round good weather, good health care options and one of the lowest crime rates in Europe, not to mention the favourable tax regime available to new residents.
A HNW individual who has not been a resident in Greece for the past seven out of the last eight tax years and makes a minimum investment of €500,000 in Greece (in real estate, businesses or legal entities based in Greece) can make a lump sum payment of €100,000 per tax year as a substitute for tax on foreign income and gains; the individual will only be subject to tax on Greek-source income.
In addition, they will be exempt from inheritance tax and gift tax on non-Greek assets. The regime can be extended to close relatives for an additional annual charge of €20,000 (per tax year per relative). Greece also offers an alternative beneficial tax regime for individuals with foreign pension income who have not been resident in Greece for the past five out of the last six tax years; if eligible the individual will pay a 7% flat rate of tax on their foreign-source income.
However, like other popular destinations for wealthy migrants, Greece has experienced pressure on its housing market and as a result has recently increased the minimum investment for those looking to obtain a "Golden visa" by purchasing real estate; the minimum investment is now €400,000, or €800,000 in certain of the more popular islands.
Ireland
Ireland's rich and diverse cultural history, breathtaking natural beauty, thriving business environment and high quality of life make it a popular destination for high net worth (HNW) individuals looking to relocate (provided they don't mind a bit of rain). The Knight Frank Wealth Report 2024 suggests that Ireland's ultra high net worth (UHNW) population will increase by just over 24% by 2028.
For any non-doms considering leaving the UK, the beneficial tax regime in Ireland for Irish residents but non-Irish domiciled individuals will seem very familiar. Such individuals are only liable to tax on foreign-source income and gains on the disposal of non-Irish assets if and to the extent they are remitted to Ireland, and non-Irish domiciled individuals are not required to report details of their worldwide income and gains.
In addition, there is no time limit on the Irish 'non-dom' tax regime, provided the individual remains non-Irish domiciled.
Italy
In addition to its weather, beautiful landscape, cuisine, and art, Italy offers UHNW individuals significant tax benefits. Individuals moving to the country for the first time (or those returning after having been non-resident for a significant period) have the option to pay a flat rate of €200,000 per tax year (increased from €100,000 in August 2024) (for up to 15 years) as a substitute for tax on foreign income and most gains (importantly, including tax on distributions from non-resident trusts).
Individuals using the flat tax regime can bring their foreign assets and income into Italy at any time without triggering Italian tax and are not subject to gift, inheritance or wealth tax on non-Italian assets. Italian source income and gains will, however, be subject to tax. You can generally acquire an Italian residence permit through investing €500,000 or more in an Italian company or €2 million in Italian government bonds.
Malta
Malta has long been a favoured destination for HNW individuals, with the number of millionaires in Malta reportedly increasing by 74% in the 10 years to December 2023.
Malta has a number of options for HNW individuals looking to enjoy the year-round sunshine, rich history and culture, and superb quality of life on offer. HNW individuals who purchase property worth at least €375,000, make a contribution to the Maltese government and a donation to a non-governmental organisation, and have at least €500,000 of capital, can obtain a residency permit under the Permanent Residence Programme.
If you take up residency under the Permanent Residence Programme you can qualify for a beneficial tax regime (subject to a minimum tax of €15,000 per annum). Broadly, you will only be subject to income tax on income (and gains) arising in Malta and on foreign-source income remitted to or received in Malta (gains arising outside Malta are not subject to tax even if remitted to Malta). If foreign-source income is remitted to Malta it is taxed at a flat rate of 15%.
Monaco
Dubbed as the "playground of the rich and famous", Monaco is currently the third fastest growing wealth hub in Europe, with millionaire growth of 68% recorded over the past decade and a projected net inflow of more than 200 millionaires in 2024, according to The Henley Private Wealth Migration Report 2024.
The report references Monaco as one of the leading 'safe haven' jurisdictions – a "sovereign state with high levels of safety and security that remains largely shielded from the world’s political and economic problems".
The attraction of Monaco for the super wealthy is obvious; as well as a luxurious standard of living in a safe and multicultural society, HNW individuals living in Monaco enjoy a beneficial tax system, with no income, capital gains, or wealth tax.
Before applying for residency in Monaco, individuals from outside the EEA must obtain a French visa. Anyone applying for residency must also provide proof of accommodation in Monaco, as well as proof of sufficient funds to live in Monaco; while there is no minimum investment requirement, individuals usually require at least €1 million for accommodation and €500,000 to deposit in a bank in Monaco as proof of financial self-sufficiency.
Portugal
Portugal has been one of the most popular destinations for HNW individuals over recent years, but the abolition of its 'non-habitual residents' tax regime and changes to its "Golden visa" to stop people acquiring a residency permit by investing in real estate appear intended to attract a new pool of talent to the country.
The revised Golden visa allows non-EU citizens to acquire residency by creating ten jobs or providing €500,000 of capital investment in specified research or cultural/heritage programmes or non-real estate collective investment entities. New rules mean individuals working in scientific research or innovation (including directors and employees of certain start-ups) who become tax resident (having been non-resident in the previous five tax years), will pay a flat 20% rate of tax on Portuguese employment and business income deriving from certain activities, and may be exempt from tax on foreign employment, business and investment income.
Spain
Spain's "Golden visa" programme will close on 3 April 2025. Individuals will no longer be able to obtain a residence permit by investing in Spanish real estate, public debt securities, bank deposits, shares in Spanish companies, or business start-ups.
However, it's clear that Spain remains keen to attract talent from abroad (including from outside the EU) with visa opportunities remaining for highly qualified professionals, certain employees and digital nomads. Its inpatriate tax regime targeted at highly qualified professionals, entrepreneurs and digital nomads, has also recently undergone a number of changes to make it more appealing. These include reducing the period of non-residence needed to be eligible from ten to five years, expanding the categories of people who qualify, and extending the benefits to close family members.
If you qualify, you can elect to be taxed as a non-resident – this means you'll only be subject to wealth tax on Spanish assets and will only pay Spanish tax on your Spanish-source income and gains, except in respect of employment income (your worldwide employment income will be taxed at a flat rate of 24% up to €600,000 and at a rate of 47% over that).
Switzerland
Switzerland, with its global 'safe haven' status, high standard of living and beneficial tax regime, has long been a favoured destination for HNW individuals. And its appeal doesn't seem to be waning. HNW individuals taking up residence in Switzerland for the first time, or after an absence of more than 10 years, may obtain a residence permit by opting for what's known as the ‘lump-sum' tax regime.
Under this regime, an individual's taxable income is predetermined based on the annual worldwide living expenses of the individual and their family; the individual's predetermined taxable income is then subject to tax at the ordinary income tax rates. Not all cantons offer lump-sum tax regimes and competition between those that do means variations in the minimal taxable income and the taxable wealth used to calculate wealth tax.
The regime is not, however, suitable for everyone. Individuals who use the regime may not perform any commercial or professional activity or seek employment in Switzerland; falling foul of this condition could risk the individual becoming subject to ordinary taxation.
The UAE
The UAE is attracting an ever-increasing number of HNW individuals, with one of the highest anticipated inflows of HNW individuals for 2024 globally. This is perhaps unsurprising given its climate, standard of living, infrastructure, financial services, healthcare and competitive tax regime – with no personal income tax, capital gains tax or gift, inheritance or wealth tax due/collected in the UAE.
Foreign nationals can obtain UAE residency under its "Golden visa" scheme by, for example, acquiring real estate with a value of at least AED2 million or investing at least AED2 million in an approved investment fund. "Golden visa" holders can also sponsor their spouses and children without the need to make any additional investment.
As a leading international private wealth law firm, we are commonly asked by our clients about the jurisdictions they should consider on a relocation. If you'd like support with relocation, please get in touch.
