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Residence and Citizenship Planning

How Governments Win Global Wealth

Philippe Amarante

Philippe Amarante

Philippe Amarante is Managing Partner and Head of Government Advisory at Henley & Partners.

Wealth mobility in 2026 is no longer simply a by-product of lifestyle preferences, business opportunities, or economic growth. It is increasingly shaped by deliberate policy choices as governments compete to attract and retain internationally mobile wealth. Tax regimes are redesigned, residence and citizenship programs are launched, expanded, or withdrawn, and policy decisions made in one jurisdiction are rapidly assessed against those of its competitors.

As a result, the relationship between governments and internationally mobile individuals has evolved. Jurisdictions offer legal certainty, institutional quality, access rights, policy stability, and attractive operating environments; globally mobile families bring investment, entrepreneurship, tax revenue, and human capital. What was once an implicit understanding has become an increasingly explicit competition, reflecting the reality that wealthy families today have more choices — and greater mobility — than at any point in modern history.

The UK’s non-dom reforms in 2025 provided one of the clearest illustrations of how quickly policy signals can influence wealth mobility behavior, accelerating international diversification planning among globally mobile individuals and families. More significantly, they demonstrated how policy developments in one major jurisdiction can shape expectations far beyond its borders.

Long-term residence and citizenship planning is therefore becoming increasingly proactive and multigenerational. Families are no longer reacting solely to the rules that exist today; they are positioning themselves for the possibility of future change. The visible precedents are accumulating, and when one major jurisdiction changes course, others increasingly see it as a signal of what may eventually follow elsewhere.

Tax: The Most Visible Lever

Of the policy levers governments hold over internationally mobile wealth, taxation is the most visible and the most closely watched. However, it is not, in our experience, the most important. Wealthy families rarely move for tax reasons alone; they weigh institutions, safety, education, family inclusion, business opportunities, and long-term predictability alongside any fiscal advantage. What tax does is move first and register fastest, which is why it so often dominates the public discussion of wealth mobility.

The UAE’s zero-personal-income-tax framework has produced sustained high-net-worth-individual inflows at scale and remains one of the clearest examples of tax functioning as a competitive policy instrument. Italy’s lump-sum regime for new residents, recalibrated in the 2026 Budget Law to EUR 300,000 with the family-member rate set at EUR 50,000, continues to attract strong demand because the underlying proposition remains compelling: a 15-year planning horizon combined with broad exemptions from Italian wealth, inheritance, and foreign-asset reporting obligations on foreign-held assets. Even at the higher headline figure, the regime remains attractive because it combines long-term certainty with a tax framework that, for many internationally mobile families, remains more favorable than ordinary Italian residence.

While Italy shows how fiscal clarity can attract mobile wealth, France illustrates the opposite risk: even proposals that do not ultimately pass can affect behavior when they signal a possible change in policy direction. In October 2025, France came within a single vote of introducing US-style citizenship-based taxation and, although the proposal was not included in the final 2026 budget, many affluent French residents continue to view it as an indication that the country’s fiscal approach could be revisited. Norway’s wealth tax similarly contributed to a reassessment among globally mobile individuals and families, prompting the government to tighten its exit-tax rules in response to significant capital and wealth leaving the country in preceding years.

Hand moving pawn on a conceptual maze. Shortcut to success or career guidance concept

Regulation: Where Coherence Beats Generosity

Tax policy alone, however favorable, does not retain or attract high-net-worth individuals where the surrounding regulatory environment fails to support it. Switzerland combines a wealth-management infrastructure of approximately USD 2.6 trillion in offshore assets under management with regulatory predictability that has held across multiple political cycles. The UAE has built equivalent infrastructure through DIFC and ADGM, and Singapore’s family office regulation through MAS has done the same in Asia.

The negative cases are equally instructive. Spain’s termination of its golden visa program in April 2025 closed the dominant entry channel for non-EU high-net-worth individuals at the same time as its wealth tax, with a top marginal rate of 3.5% on net assets, remained in force. And Portugal’s 2023 closure of the real estate route under its Golden Residence Permit Program drove additional inflows to Italian and Greek alternatives.

Migration Policy: Access as the Binding Constraint

The third lever is the one most governments still underestimate. Migration policy — investor visa programs, residence pathways, citizenship timelines, dependent rights — is the legal infrastructure through which high-net-worth-individual mobility actually happens, and where access is broken or blocked, neither tax nor regulatory advantages translate into measurable inflows.

The UAE Golden Visa has been the most effective access framework of the past five years, combining processing speed and efficiency with long duration, flexible physical presence requirements, and dependent inclusion. New Zealand’s relaunched Active Investor Plus Visa Program has shown how quickly a redesigned and optimized pathway converts into demand. The UK, by contrast, closed its Tier 1 Investor Visa in February 2022, removing its principal entry route for foreign high-net-worth individuals at the same time that subsequent policy reforms were reshaping the proposition for internationally mobile residents already living in the country. In wealth mobility terms, it was a rare example of a major economy simultaneously weakening both its attraction and retention proposition.

Reading Policy as Data

Governments contending for mobile wealth are competing on these three variables specifically, because they are the only ones they can credibly differentiate on. Climate, geography, language, and culture are largely fixed; tax, regulation, and access are not.

The Global Wealth Mobility Framework introduced in this report is built to read those variables across jurisdictions. Each country is assessed on twelve weighted dimensions, grouped across five pillars covering access, attractiveness, competitiveness, resilience, and optionality, with every score anchored to reliable published data so that the basis for any result can be checked rather than taken on trust. The weighting follows the evidence of what internationally mobile families actually consider: rule of law and quality of life sit alongside tax treatment at the top, the design of investor programs and the pathway to permanent residence and citizenship carry substantial weight, and family inclusion, geopolitical stability, and capital mobility follow close behind.

The framework is what allows us to read policy not as commentary but as data: measurable across jurisdictions, comparable across time, and a directional guide to where the conditions for attracting and retaining mobile wealth are strengthening or weakening. Where earlier analysis could identify that wealth was moving and roughly where, the framework allows us to identify why, and in response to which specific instruments.

The Retention Problem

Most public discussion about wealth migration focuses on attraction. However, for established economies, the harder question is retention. Attraction works through marginal incentives: a tax break for a new arrival, a fast-track visa, a residence permit linked to a real estate investment. Retention works through credible commitment over time, and in many established economies the honest answer to whether the rules under which a wealthy family built its life will still apply in 15 years is now uncertain.

Governments facing fiscal pressure have increasingly looked to the existing wealthy resident base as a near-term revenue source on the implicit assumption that the population would absorb the change and remain in place. The UK non-dom abolition, the Norwegian wealth tax increase, the French citizenship-based taxation vote, the Spanish wealth tax sustained alongside the golden visa closure: each was designed on the premise that the established resident base was relatively captive. The 2026 data shows that premise no longer holding.

How Governments Compete for Mobile Wealth

Three factors separate the governments gaining ground in 2026 from those losing it. The first is coherence, meaning policy packages designed across tax, regulation, and access together rather than optimized on any one of them alone. The second is predictability across a planning horizon long enough to match the one high-net-worth individuals themselves use. And the third is competitive positioning calibrated against a global benchmark rather than a regional one.

The competitive set now includes the UAE, Singapore, the Caribbean, Portugal, Italy, Switzerland, the USA and a growing list of newer entrants from Saudi Arabia to Uruguay. Getting the three factors right is what attracts mobile wealth; keeping it requires the harder work that this year’s data shows most established economies have not yet done.

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