Private wealth shuffle: Uncovering the latest relocation trends of fortunes
“Capital goes where it is welcome and stays where it is well treated” – Walter Wriston (former CEO of Citigroup)
As some nations grapple with an unprecedent outflow of their wealthy population, others are positioning themselves as magnets attracting these individuals and their families. As we stand on the cusp of the largest intergeneration transfer of family wealth ever (the “Great Wealth Transfer”1), (ultra) high net worth individuals (HNWIs) are increasingly concerned about the protection of their wealth.
This second article of a series devoted to some of the current key trends, opportunities and challenges of the international wealthiest families aims to explore how some nations are positioning themselves to attract HNWIs.
In the wake of an historic year in which more than 50% of the world’s population went to the polls – a record since the creation of universal suffrage – some of the major economic hubs are experiencing an exodus of their wealthy population. While in the last decade the number of HNWIs across the world along with their wealth has significantly increased , this unrivalled relocation of wealth is taking place in a global unstable (geo)political and economic context. As some nations observe their HNWIs’ population flee, new jurisdictions are rapidly emerging as magnets for these individuals, reshaping the private wealth landscape.
Since 2019, the annual relocation of HNWIs across the world has increased by 16% reaching an unprecedented 128,000 relocations in 20243 whilst forecasts for 2025 (i.e. 135,000) exacerbate this exodus trend. China and the United Kingdom, respectively second and third countries hosting the most HNWIs4, are currently facing an exodus of their wealthy population and topped the ranks of the countries with the highest net outflow of HNWIs. While Chinese millionaires are mainly driven to leave the Middle Kingdom by a tense geopolitical context and a faltering economy, on the Old Continent, the UK based HNWIs and their families are fleeing away in response to the political instability and the race to bail out public deficits leading to the redefinition of the domestic “contrat social”. Across the Channel, France, fifth country with the most (ultra) HNWIs5, may also experience a similar situation as its wealthiest might get tired to shoulder a poorly managed public indebtedness by a government announcing new tax reforms6. Last but not least, as we finalise this paper, President Trump elected 2 months ago in the US just announced new tariffs smashing global trade norms. To a certain extent the unpredictability and bold political choices of the new US administration may encourage wealth creators and their families to relocate outside of the United States.
When ultra wealthy individuals envisage relocating their residence, there does not appear to be “one fit all” pulling factor. From political stability, personal safety to premium infrastructures, HNWIs take a wide range of factors into consideration when considering their new home country7. Combined with a favourable tax regime8, these elements appear as the ideal combination for attracting private wealth.
Which countries are emerging as the preferred destinations for (ultra) HNWIs, and what are the driving forces behind their relocation choice?
Switzerland and Italy: The European champions
While the United Kingdom is experiencing an exodus of private wealth, 68% of its leaving wealthy population intends to continue to have its residence in Europe9. A great opportunity for Italy and Switzerland, two jurisdictions offering a pleasant combination of an attractive tax regime and a relaxed and quiet lifestyle.
The legacy of Switzerland as a hub for HNWIs is steeped in history, tracing back to its long-standing tradition of economic stability and political neutrality. Its reputation as one of the world’s most secure locations for wealth management, with banks offering deep-rooted expertise in wealth management and private banking services, attracted generations of wealthy individuals seeking privacy and security. Switzerland has consistently maintained its position as a global epicentre for private wealth.
Beyond the financial factor, Switzerland's high quality of life, encompassing superior healthcare, education, and a multicultural environment at the heart of Europe, makes it an ideal domicile for Ultra HNWIs. In addition, some Swiss cantons offer an attractive tax regime to foreign nationals, the so-called expenditure-based tax regime (imposition d’après la dépense or “forfait”). This regime initially appears at the end of the 19th century. It is a unique tax regime dedicated to non-Swiss nationals settling in the country for the first time (or after an absence of at least ten years) and who do not carry out lucrative activities in the country. Once tax ruling filed and administrative process completed, individuals are subject to a tax computed on their living expenses (instead of actual income and assets) at a rate ranging from 20% to 45% depending on the canton of residence. For European Economic Area nationals, the minimum annual tax liability ranges between CHF 100,000 and CHF 160,000 while income tax for citizens of third-party countries (i.e. not members of the EU or EFTA) ranges between CHF 250,000 and CHF 400,00010. This regime is used by a limited number of Ultra HNWIs (deriving exclusively passive income). As an illustration, only 4,557 benefited from the regime in 2018 - corresponding to less than 0.1% of the total Swiss taxpayers. Furthermore, some Swiss cantons do not levy inheritance tax on the transfer of assets to surviving spouse and children. This is a significant advantage especially as we approach the Great Wealth Transfer.
As a result, between 2022 and 202311, Switzerland topped the list of European countries for net inflows of HNWIs, drawing in considerable private wealth. However, in 2024, the Helvetian nation saw its position as (European) leader slip away to the benefit of a neighbouring country, which has experienced an exponential increase in arrivals.
Beyond the Alps, Italy has steadily become a magnet for HNWIs for some years now, claiming the title of the European country with the largest net inflow of HNWIs in 202412. Its allure for wealthy individuals and families is rooted in a combination of its rich cultural heritage, enviable lifestyle and advantageous fiscal policies. The historical charm of the Bel Paese residing in its luxury real estate market in diversified picturesque landscapes, from the Mediterranean Sea to the Alps, and its world-renowned cuisine make it a destination to enjoy the best of European sophistication and comfort. With its strategic location in the Mediterranean, Italy also serves as a gateway to European markets.
Since 2016, individuals becoming “new” resident in Italy (or not being resident in at least 9 years of the 10 years prior the first year of application of the regime) may benefit from a lump-sum tax regime, making the country even more attractive for ultra HNWIs. This regime, available for 15 years, allows new residents (subject to a preliminary ruling with the Italian tax authorities) to pay “only” an annual lump-sum tax of EUR 200,000 on income and gains generated from non-Italian assets (with the exception of capital gains realised on substantial shareholdings during the first five years of residence). This alternative tax applies instead of the standard income tax and regardless of the amount of income and gains from foreign sources. In addition, individuals benefiting from the lump-sum regime are not subject to inheritance and gift tax on their non-Italian assets, a significant pull factor in prevision of the Great Wealth Transfer. Individuals not holding citizenship of a Member State of the European Union or the European Economic Area can secure the right to reside in Italy, and benefit from the domestic lump-sum tax regime, through investment visa, which requires inter alia a minimum investment of EUR 500,000 in an Italian company, or an elective residence visa, contingent upon demonstrating adequate income to support living in Italy. In August 2024, the government increased the lump-sum from EUR 100,000 to EUR 200,000. This was a response to the extraordinary increase of net inflow of HNWIs between 2023 and 2024 from 600 to 2,2001314. The flow of HNWIs relocating to Italy increased in 2024 and will continue to rise further in 2025 and the coming years.
Dubai: The undisputed international magnet
For three consecutive years, the United Arab Emirates (UAE), and especially Dubai, has featured in the top three jurisdictions witnessing the most net inflows of HNWIs, continuing to attract more and more wealthy families. Following the pandemic, the UAE witnessed a net inflow of HNWIs in 2022 of 5,20015 bolstered by the exodus of Russians fleeing their country hit by the war and international sanctions. After a slight drop of arrivals in 2023, when the country was still second in the list of countries attracting the most HNWIs, it regained its attractiveness in 2024. Outperforming all the other countries by having a net inflow of an unprecedent 6,700 HNWIs, it is the top choice of relocation for ultra HNWIs last year16.
In ageing western societies healthcare and security are becoming more important than ever. The Emirates are catering the needs of affluent new residents by offering premium healthcare. In addition, the political domestic stability of the country, coupled with stringent law enforcement, ensures a secure setting for personal and financial endeavours. Moreover, the high standard of living in the UAE as well as its very well-connected airports are significant draws when HNWIs consider relocating. Its central location between Europe, Asia and Africa attracts wealthy families from around the World. They may gain access to a golden visa, allowing them to benefit from up to 10 years by investing AED 2 million (approx. EUR 500,000) in the country (i.e. deposit, capital, real estate or donation) or, as recently announced, in super-yachts registered in Dubai or Abu-Dhabi. The appeal of the Emirates is greatly enhanced by the absence of income, capital gains and inheritance taxes for resident individuals. The prominence and desirability of the UAE on the world stage for HNWIs opting for it as their home is set to rise further17 solidifying the position of the Emirates as leading global hub for private wealth.
Conclusions
A handful of jurisdictions have decided to provide a competitive offer including modern infrastructures, stable environment and tax efficient regimes to attract ultra HNWIs and their families. A couple of European countries are successful in this respect. However, other valuable options exist outside of Europe. From a European perspective, being competitive in attracting wealth creators and their families will be decisive to secure private investments and innovations needed for EU economies going forward. If at one point Europe is not seen any more as a safe and stable region, some ultra HNWIs may decide to opt for other alternatives such as the Emirates or Singapore.
Luxembourg “ticks” boxes to easily become a first-choice European jurisdiction for (ultra) HNWIs (i.e. stability, security and strategic location). An attractive, simple and efficient tax regime for wealthy families may allow the jurisdiction to raise its profile in this segment. It is worth mentioning that, if properly structured, (ultra) HNWIs resident in Luxembourg could already enjoy a very competitive tax position in Luxembourg.
After analysing the current main trends in the migration of ultra HNWIs, it will be key to analyse the main options available to the wealthy families for the structuring of the holding and management of their estate in a cross-border context. Luxembourg is definitely a key jurisdiction for setting up and managing family holdings and funds entities.
This article originally appeared in Agefi Luxembourg, see link here (page 19)
1 The New York Times, “The Greatest Wealth Transfer in history is here, with familiar (rich) winners”, 14 May 2023.
2 Capgemini Research Institute, “World Report Series 2024, Wealth Management”.
3 Henley & Partners, “The Henley Private Wealth Migration Report 2024”, 18 June 2024.
4 UBS, “Global Wealth Report 2024”.
5 Knight Frank, “The Wealth Report”, 18th edition, 2024.
6 Please refer to our article “Private Wealth in motion: The great exodus”, AGEFI Luxembourg, 17 February 2025, for further details on the migration of HNWIs from the United Kingdom (and potentially France going forward).
7 Andrés Solimano, “Global Mobility of the Wealthy and their Assets: An Overview, IMC-RP 2018/2”, 2018.
8 Enea Baselgia, Isabel Z. Martinez, “Mobility responses to special tax regimes for the Super-Rich: Evidence from Switzerland”, CESifo Working Paper No. 11093, April 2024.
9 Henley & Partners, “WEXIT: Wealthy Brits Exit UK for EU Ahead of Budget”, 22 October 2024.
10 Grégoire Uldry, Alexia Egger Castillo, “Relocating to Switzerland: lump-sum tax regime”, 10 December 2024.
11 Henley & Partners, “Henley Private Wealth Migration Report 2023”.
12 Henley & Partners, “Henley Private Wealth Migration Report 2024”.
13 Henley & Partners, “Henley Private Wealth Migration Report 2023” and “Henley Private Wealth Migration Report 2024”.
14 Corriere della Sera, “Super ricchi in Italia, la flat tax radoppia a 200 mila euro ma non scoraggia i paperoni : ecco perché”, 9 August 2024.
15 Henley & Partners, “Henley Private Wealth Migration Report 2023”.
16 Henley & Partners, “Henley Private Wealth Migration Report 2024”.
17 UBS, “Global Wealth Report 2024”.
