At a glance
- UK non-dom regime abolished from 6 April 2025, replaced by a four-year FIG/inpatriate regime — according to Henley & Partners, the UK lost an estimated 10,800 millionaires in 2024 and could lose 16,500 in 2025.
- EU programs are tightening: Malta’s classic CBI is terminated, Spain’s Golden Visa abolished in April 2025, Greece’s thresholds rose to €800,000 in prime zones, and Italy’s flat tax jumped to €300,000.
- The US “Gold Card” is an Executive Order (signed September 2025) with $1M individual / $2M corporate thresholds — not the $5M congressional statute originally proposed. EB-5 remains operational.
- Global HNWI migration is forecast to hit 165,000 net moves in 2025, up from 134,000 in 2023 and 142,000 in 2024.
HNWI migration is accelerating as tax-residency rules and investor-program policies shift across major economies. With global millionaire migration forecast to reach 165,000 net moves in 2025 — up from roughly 134,000 in 2023 — clients are benchmarking newer hubs while traditional gateways tighten or close. This guide maps the current landscape with verified 2025–2026 data so you can stress-test residency, citizenship, and investment pathways across multiple jurisdictions.
The great millionaire migration: who is moving and why
According to Henley & Partners and New World Wealth, an estimated 10,800 millionaires left the UK on a net basis in 2024, with a forecast of roughly 16,500 departures in 2025 — the largest single-country outflow ever projected. These figures remain disputed by the Tax Justice Network, which argues the exodus narrative is overstated, and official HMRC data has not yet been released. Regardless, the UBS 2024 Global Wealth Report projected a roughly 17% decline in UK dollar-millionaires by 2028 (from 3.06 million to 2.54 million), a figure widely paraphrased as “nearly one in six.”
The trigger is clear: the UK abolished its non-domiciled tax regime on 6 April 2025, replacing it with a Foreign Income and Gains (FIG) regime that offers only a four-year window of favorable treatment for qualifying recent arrivals. Transitional provisions include 50% foreign-income tax relief in 2025/26, a 12% repatriation facility through 2026/27, and asset rebasing to April 2019 values. For long-standing non-doms, these terms represent a sharp reduction in planning flexibility.
The UK is not alone. Globally, net outflows are concentrated in a handful of origin countries: Russia (approximately 15,000), India (8,000), Hong Kong (3,000), and Brazil (2,500) according to Henley’s 2024 data. Institutional capital is following individuals — holding companies, family offices, and fund structures are relocating in what analysts call a “silent migration” of corporate substance.
Policy drivers reshaping tax residency and alternative citizenship
Four converging policy currents are reshaping the investment-migration landscape in 2025–2026:
UK non-dom abolition. The removal of remittance-based taxation is prompting high earners to reassess tax residency. The replacement FIG regime’s four-year limit means anyone who arrived before April 2021 has already exhausted favorable treatment. Large-scale relocation to the UAE, Switzerland, and Italy is well documented.
EU tightening on citizenship and residence by investment. The EU’s top court ruled against Malta’s “golden passport,” and Malta’s classic CBI has been terminated — only the ESDI naturalisation pathway remains, requiring €600,000 (after three years’ residence) or €750,000 (after one year), plus a €700,000 property purchase or €16,000/year rental and a €10,000 donation. Spain abolished its Golden Visa entirely via Organic Law 1/2025 (effective April 2025). Portugal closed real-estate routes in October 2023; the primary option is now a €500,000 investment-fund route. FATF and OECD compliance pressure continues to squeeze Caribbean CBI programs, with several microstates deriving 10–40% of GDP from these schemes.
Greece’s new two-zone thresholds. Greece implemented a tiered Golden Visa system: €800,000 for Attica, Thessaloniki, Mykonos, Santorini, and islands with more than 3,100 residents; €400,000 for all other regions (single property of at least 120 m²); and a €250,000 exception for commercial-to-residential conversions only.
US Gold Card Executive Order. On 19 September 2025, the White House signed the “Gold Card” Executive Order setting a $1 million individual (or $2 million corporate-sponsored) gift threshold to the Department of Commerce. This is not the $5 million congressional statute that was originally discussed — it is an EO that directs expedited processing of EB-1 and EB-2-NIW immigrant visas. It does not guarantee automatic green cards or citizenship; the standard five-year path to naturalization applies. Over 70,000 expressions of interest were registered, with 1,000+ in a single hour on launch day. The EB-5 program remains fully operational alongside it.
Emerging hubs to benchmark now
As traditional European centers recalibrate, HNWIs are gravitating toward jurisdictions perceived as tax-efficient and mobility-friendly. The top destinations currently drawing millionaire inflows include the UAE, USA, Switzerland, Italy, and Greece.
UAE. Zero personal income tax, no capital-gains tax, and a well-developed golden-visa framework (roughly $545,000 property investment for a 10-year visa) make Dubai and Abu Dhabi the top global HNWI destination. The UAE also offers crypto-friendly regulatory frameworks that are attracting tech entrepreneurs and fund managers.
Switzerland. Lump-sum taxation (forfait fiscal) remains available in most cantons for foreign nationals who do not work in Switzerland, calculated on living expenses rather than worldwide income. Combined with political stability, banking infrastructure, and central European location, Switzerland continues to attract ultra-high-net-worth families.
Italy. Italy’s flat-tax regime for new residents has been increased to €300,000 per year for the main taxpayer plus €50,000 per dependent, as provided by Italy’s 2026 Budget Law. Existing beneficiaries are grandfathered at the prior rate. Despite the increase from the original €100,000, this regime still attracts HNWIs relocating from higher-tax jurisdictions.
Montenegro. An emerging option in Southeastern Europe with investor-citizenship discussions ongoing, favorable tax rates (9% corporate, 9–15% personal income), and EU candidate status that adds long-term strategic value for mobility planning.
Strategic playbook for law firms and HNWIs
In an environment where rules change quickly, cross-border planning must be iterative and tax-led:
- Start with tax-residency diagnostics. Map current domicile and residency status and identify trigger points — day counts, center of vital interests, investment-income flows. This helps mitigate unexpected tax exposure during transitions.
- Model multi-jurisdiction outcomes. Compare after-tax scenarios for two or three target jurisdictions (e.g., UAE vs. Switzerland vs. Italy vs. Armenia) reflecting the client’s income mix and physical-presence requirements.
- Align immigration route with tax logic. Where golden visas or tailored residence permits exist, confirm that visa timelines, minimum presence, and renewals dovetail with tax-residency and treaty planning.
- Pre-move clean-up. Rebase assets, address PFIC/CFC issues, and coordinate trust and succession structures to avoid multi-country reporting burdens for heirs.
- Plan for program shifts. Build “Plan B” and “Plan C” routes in case a favored program tightens eligibility or pricing — as seen with Spain’s Golden Visa closure and Malta’s CBI termination.
Jurisdiction comparison checklist
Use this checklist to benchmark emerging hubs for HNWI migration and tax-residency objectives.
| Criterion | What to verify |
|---|---|
| Tax regime | Effective rates on dividends, capital gains, wealth/inheritance, remittance rules, exit taxes |
| Entry route | Residency vs. citizenship, investment thresholds, program stability, EU/US scrutiny exposure |
| Physical presence | Day-count requirements and substance tests that determine residency outcomes |
| Treaty network | Double-tax and information-exchange considerations for key income streams |
| Family coverage | Spouse/children inclusion, education, and healthcare access alongside visa validity |
| Banking & markets | Account opening, private banking, currency controls, market access |
| Reputation & compliance | Sanctions exposure, due-diligence standards, FATF/OECD alignment, and program reliability |
| Exit options | Ability to unwind or pivot if policies tighten (e.g., Spain’s Golden Visa closure, Malta’s CBI termination) |
Action steps when rules change mid-plan
Because program terms can shift rapidly, embed these actions in your playbook:
- Freeze-frame your facts. Capture current day counts, treaty relief, and asset positions before changing residence to prevent unintended tax exposure.
- Secure interim mobility. Maintain a valid visa or residence bridge while reassessing options. Where golden-visa alternatives exist, confirm continuing eligibility.
- Re-cost the plan. Update cash flows for new investment thresholds or fees — e.g., Greece’s jump to €800,000 in prime zones, or Italy’s flat tax increase to €300,000.
- Protect legacy and heirs. Reconcile trusts, wills, and intergenerational transfers with new jurisdictional rules to avoid cross-border estate complications.
- Document exit and entry positions. Evidence your tax departure and new residency to support filings and audits across both jurisdictions.
How our Armenia-centric team supports cross-border plans
Our cross-border practice blends immigration, tax, and corporate work to help clients coordinate multi-jurisdiction pathways — and maintain optionality when rules change. If you are exploring a diversified EMEA strategy, we can structure residence, business formation, and investment vehicles in tandem with your global plan:
- Explore residency pathways aligned with your day-count and substance goals.
- Coordinate business registration and bankability with mobility and governance needs.
- Model tax outcomes across alternative bases and holding structures.
- Integrate citizenship, visa, and investment considerations for long-term resilience.
Conclusion
HNWI migration is being redefined by tax-residency and policy shifts: the UK’s non-dom abolition, EU scrutiny of alternative citizenship, and evolving investor-visa thresholds are pushing wealth toward jurisdictions like the UAE, Switzerland, Italy, Greece, and — increasingly — Armenia. Global net millionaire migration is on track to surpass 165,000 in 2025, and the regulatory landscape continues to tighten. The winners will be clients and advisers who build agile, tax-led, cross-border plans and maintain multiple routes in case programs close or costs rise.
