Over 135,000 millionaires are predicted to migrate from their country of residence in 2025, with China and the United Kingdom1 seeing the largest outflows. These “net outflow” figures are counterbalanced by countries experiencing “net inflows.”
You may be interested to know that Utmost Group has a presence in, or a portable value proposition for, at least seven out of the top 10 “net inflow” countries attracting globally mobile wealthy families. We also have coverage in six out of the top eight countries often cited as “safe havens,” an increasingly important consideration in wealthy families’ relocation plans.
So, which countries are set to benefit from these inflows, and what are the main attractions and considerations? Here are a few:
1. United Arab Emirates (UAE)
Attractions: Taking top spot with most predicted net inflows, the UAE rates highly on personal safety, ease of entry, and no personal taxes.
Considerations: Despite the UAE’s tax-free status, residents can become “accidental taxpayers” by failing to plan with their global investment portfolios. A big trap for the unwary is the lack of a double tax treaty with the US, potentially exposing UAE residents to US withholding taxes and Estate Tax on their US assets. Furthermore, the recently introduced corporation tax can apply to family investment companies, even if structured offshore. With planning, these problems are solvable.
2. Portugal
Attractions: Climate, lifestyle, no Inheritance Tax.
Considerations: Recent dilution of the non-habitual residence regime means that fewer individuals will qualify to use this attractive tax regime, thus exposing their wealth to higher rates of tax. Although there is no inheritance tax, Portugal does have a 10% Stamp Duty which can bite on the transfer of certain assets on death. With careful planning, tax on investments can be driven as low as 11.2%, and assets can be passed on free of capital gains tax and stamp duty.
3. Italy
Attractions: Climate, lifestyle, and four special “expatriate” tax regimes, including an attractive regime for HNW individuals allowing them to pay a flat €200,000 in tax for 15 years.
Considerations: Expatriate regimes are designed to incentivise people to stay for the longer term. If a client chooses to do so, it’s important to consider structures that will last beyond the special tax “time bar”. Doing so can reduce income tax and inheritance tax exposure on wealth for the longer term.
4. Monaco
Attractions: Personal safety; no personal taxes.
Considerations: Like UAE, individuals can become “accidental” taxpayers due to the lack of a double tax treaty network, and, in relation to succession planning, failure to consider the tax exposure in the countries where beneficiaries reside. Furthermore, there is inheritance tax in Monaco, which can apply even to foreign assets if these are not structured properly. With planning, these issues can be addressed.
5. Australia
Attractions: Climate, lifestyle, no Inheritance Tax.
Considerations: Whilst Australia has no inheritance tax, it does rank among the top jurisdictions for income taxes, with marginal rates of up to 47%. It also has wide-ranging anti-avoidance provisions that punitively tax offshore trust and company structures. With planning, however, it is possible to shelter investments in a way that reduces tax on investments to zero.
1 Source: The Henley Private Wealth Migration Report 2024