On 6 April 2025, the United Kingdom abolished a 226-year-old tax regime. The non-domiciled (non-dom) status, which had allowed wealthy residents to live in Britain while paying tax only on UK-source income, ended overnight. Foreign assets, foreign trusts, and foreign income all came under the British net. For roughly 74,000 affected residents, the calculation changed in a single fiscal stroke.
Some of them stayed. Others did not. The Henley Private Wealth Migration Report projects the UK will lose 16,500 millionaires in 2025 alone, taking an estimated 66 billion pounds in investable assets with them. That figure is more than double the prior year, and it is the first time in the decade Henley has tracked these flows that a European country has led the world in outflow.
The UK is the most visible chapter of a much larger story. In 2025, a record 142,000 millionaires are projected to relocate internationally. Among the world's billionaires, the UBS Billionaire Ambitions Report finds that 36% have already changed country of residence at least once, and among those aged 54 and under, the figure rises to 44%. What used to be a quiet feature of family-office strategy is now a structural feature of the global wealth economy.
This piece looks at the numbers behind the migration, where the money is going and why, the policy shifts driving it, and how branded real estate has become the practical instrument families use to convert intention into a residency.
The scale: a record year, decade-defining trends
Three datasets, taken together, define the moment.
- Henley & Partners recorded 142,000 millionaires migrating across borders in 2025 - the largest figure since the firm began tracking these flows in 2013.
- UBS surveyed 87 billionaire clients across Switzerland, continental Europe, Singapore, Hong Kong, and the United States between July and September 2025. 36% had already relocated at least once; a quarter of those had relocated more than once. 9% were actively considering a move at the time of the survey.
- Residency-by-investment intake data tells the same story from a different angle. Top advisory firms report application volumes up roughly 28% year-on-year, with the surge concentrated in programs that offer multi-decade residency without onerous physical-presence requirements.
It is worth acknowledging that the Henley figure is contested. Tax Policy Associates and others have noted that the 16,500 UK departure number relies on LinkedIn and proprietary models rather than HMRC tax returns, and that the directional signal may be stronger than the precise count. The directional signal is what matters here. Even sceptical analyses agree that the UK net outflow is rising sharply; the question is whether the absolute number is 8,000 or 16,500. Either is a material shift from a decade of net inflow.
What used to be a quiet feature of family-office strategy is now a structural feature of the global wealth economy.
Why now: from optimistic to defensive migration
Historically, wealthy families relocated for opportunity. They followed talent, growth markets, and lifestyle. The 2010s migration story was San Francisco, Singapore, and London - places where new wealth was being created and where ambition was rewarded.
The 2026 story is different. According to UBS, the top three reasons billionaires cite for relocating now are, in order, better quality of life (36%), geopolitical concerns (36%), and the ability to organize tax affairs efficiently (35%). The geopolitical line was not in the top three even five years ago.
Three forces explain the shift.
1. Policy volatility has compressed
Tax regimes that used to take decades to evolve now change inside a single electoral cycle. The UK is the marquee example, but it is not isolated. Norway raised wealth taxes in 2023 and saw an immediate exodus of high earners to Switzerland. France has dropped from a net-inflow country to a net-outflow country in 2025 (-800 net). Spain ended its golden visa program in April 2025. Italy, which had positioned its 100,000-euro lump-sum tax as the most generous regime in Europe, raised the rate to 200,000 euros for new joiners in late 2024 and to 300,000 euros from January 2026.
When the rules of a jurisdiction can be rewritten in 18 months, the value of holding only one passport falls.
2. Sovereignty concerns are no longer abstract
Digital surveillance, capital controls, and the speed of sanctions regimes since 2022 have made jurisdictional risk a board-level conversation inside family offices. Reporting requirements that were paperwork five years ago - the US FBAR, Common Reporting Standard, beneficial-ownership registers - have become a reason to think harder about which jurisdiction has primary claim on a family's affairs.
3. The motivation has flipped from offense to defense
Earlier waves of wealth migration were about reaching for the next opportunity. The current wave is about insurance. UBS describes this as the rise of "plan-B thinking" inside billionaire families - the move is not necessarily to leave, but to have somewhere fully ready to go. Asset protection, intergenerational continuity, and operational flexibility now sit ahead of pure tax arbitrage in the brief most family-office principals give their advisors.
Who is losing wealth
The Henley 2025 outflow projections, ranked:
- United Kingdom: -16,500 net HNWI. First European country to lead the global outflow ranking in the report's decade-long history. The non-dom abolition (April 2025) and the inheritance-tax and CGT changes of October 2024 are the proximate triggers.
- China: -7,800. The number has been declining year-on-year for five years, but China remains the second-largest source of outbound HNWIs.
- India: ranked third for outflow, even though India also continues to mint new millionaires faster than any country in the world.
- Russia: still significant outflow as sanctions-era restructuring continues.
- First-time entrants on the outflow list in 2025: France (-800), Spain (-500), Germany (-400). The fact that three EU heavyweights are now net-negative is the structural story behind the UK headline.
There is one common thread across the outflow countries: each has, in the past 24 months, either raised taxes on high earners, restricted residency-by-investment, or both. Markets price in policy in months. Families do it more slowly, but they are doing it now.
Where the money is going
The 2025 inflow leaderboard:
- United Arab Emirates: +9,800 net HNWI. Fourth consecutive year as the world's leading wealth-inflow market. The 10-year Golden Visa (residence by 2 million AED real-estate investment, roughly 545,000 USD), zero personal income tax, and a stable regulatory environment have made it the default "first-stop" for outbound HNWIs.
- United States: +7,500 net. Despite the renunciation noise (more on that below), the US remains the world's second-largest wealth magnet. The pull is structural - depth of capital markets, currency, language, and the dominance of US technology platforms.
- Italy: top-three destination. The 200,000-euro lump-sum tax regime (rising to 300,000 euros for new entrants from January 2026) covers all foreign-source income for 15 years. Combined with quality-of-life and EU access, Italy has quietly become the European jurisdiction of choice for outbound UK non-doms.
- Switzerland: still in the top five. The cantonal lump-sum tax (Pauschalbesteuerung) remains attractive for the largest balance sheets, where the fixed annual amount is small relative to total income.
- Saudi Arabia: +2,400. The biggest riser on the 2025 list. Vision 2030 incentives, a new Premium Residency program, and the Riyadh financial-sector buildout are pulling regional and South Asian capital that previously defaulted to Dubai.
- Portugal: Golden Visa volumes surged in 2025-2026, with Americans the top nationality of applicants and the UK in second place. Portugal removed real-estate as a qualifying asset class in October 2023, but the fund-investment and qualifying-business routes have absorbed and grown the demand.
What the destinations share is not a single ideology. The UAE is a low-tax monarchy; Italy is a high-tax EU member that grants a fixed-cost exception. The US is structurally messy. What they share is policy stability. A buyer can model what the next decade looks like in those jurisdictions with reasonable confidence. That is increasingly rare.
The instruments: how families actually move
Most relocations are not single-step. They proceed through three instruments, often used in combination.
Residency by investment
Often called "golden visa" programs, these grant a multi-year residence permit in exchange for a qualifying investment - typically real estate, government bonds, a fund commitment, or business creation. The UAE Golden Visa (10 years, real-estate route) is the most active program in the world by volume. Italy's Investor Visa and the Investor Permit programs in Greece, Portugal (fund-based), and Hungary (re-opened in 2024) are the principal EU options. Most of these allow family inclusion and have minimal physical-presence requirements.
Citizenship by investment
Fewer programs remain. Malta's citizenship program was struck down by the European Court of Justice in April 2025. Cyprus closed its program in 2020. The active Caribbean programs (Antigua, Dominica, Grenada, St. Kitts, St. Lucia) remain functional and have raised price floors. For families seeking a true second passport rather than residency, the Caribbean and Vanuatu are the practical options.
Real estate as the qualifying asset
Inside almost every active residency program, real-estate investment remains the most popular qualifying route. There are three reasons. First, it is an asset the family will use or rent, not a paper investment that produces no utility. Second, it converts a tax outlay (the lump-sum or program fee) into an asset on the family balance sheet. Third, and least obvious, a branded residence in a recognized address satisfies the soft criteria that immigration officers, private bankers, and the family's own internal succession planning all rely on. A unit at ORLA Dorchester on Palm Jumeirah or at Tierra Viva by Lamborghini in Benahavis reads, in any room, as a serious address. That signaling value matters more in 2026 than it did in 2015.
The American factor: even US citizens are leaving
The United States is the only major country where citizenship, not residency, is the tax-relevant variable. US citizens are taxed on worldwide income regardless of where they live. That structural fact has produced a small but accelerating renunciation phenomenon.
Federal Register data shows US citizenship renunciations rose roughly 102% year-on-year in Q1 2025. The Boundless 2025 Expatriation Report estimates the renunciation queue at over 30,000 people - up from approximately 18,000 in 2023. Among long-term US expats, the share considering renunciation jumped from 30% to 49% between 2024 and 2025.
The narrative that renouncers are the ultra-wealthy is partly wrong. IRS data shows roughly a third of renouncers reporting net worth qualify as millionaires; the rest are middle-income long-term expatriates and dual citizens. But the directional movement is unmistakable. For the first time, expatriation is being discussed inside US-resident families, not just by Americans abroad.
For families considering this path, the calculation is rarely just tax. It is also FBAR and FATCA reporting fatigue, generational planning for children born outside the US, and the asymmetric exposure of US passport-holders to global geopolitical risk.
What this means for branded residences
The intersection of capital migration and branded residential real estate is now the most interesting niche in luxury property. Three observations.
- Residency programs increasingly accept branded inventory as qualifying investment. The UAE Golden Visa accepts any real estate at or above 2 million AED, which most branded units in Dubai exceed by definition. Italy's investor visa accepts any qualifying property, with the lump-sum tax then handling the foreign-income side. Portugal's fund route can be paired with a non-qualifying real-estate purchase for lifestyle use.
- Brand and operator are functioning as risk mitigants. For a family using property as part of a residency strategy, the building's operator becomes the local agent they will interact with weekly. A brand-operated residence with a known management standard is significantly less administrative friction than a non-branded condo with a rotating HOA.
- Multi-jurisdiction portfolios are concentrating in branded inventory. Family offices building geographic optionality are not buying a flat in each of six cities. They are buying one branded residence in each of two or three jurisdictions - one in Dubai, one in southern Europe, one in the US - because branded inventory amortizes their attention budget.
A framework: the three-jurisdiction question
For families building a migration strategy from scratch in 2026, the practical question to start with is not "where should we move?" It is "which three jurisdictions should we hold?"
- Where you live. The primary residency. This is the jurisdiction whose tax code dominates and whose schools, hospitals, and political system shape day-to-day life.
- Where you bank. Often the second residency or the citizenship-by-investment passport. The jurisdiction that holds the operating accounts and ideally has the broadest banking-secrecy and capital-mobility regime compatible with global compliance.
- Where your business sits. The jurisdiction of incorporation and operating activity. Often separated from the personal residence for the past decade and increasingly so now.
Each of these should ideally be independent of the others, so that a policy shock in one does not compromise the family across the board. Branded real estate sits most naturally at position one - the residence - but increasingly anchors position two as well, when the property qualifies for the secondary jurisdiction's investor program.br
The geography of private wealth is being redrawn. For HNW families, residency is now a portfolio-level decision.
The bottom line
Capital migration in 2026 is not a story about the rich avoiding tax. It is a story about families re-architecting their geography after a decade in which policy stability stopped being the default assumption. The UK's non-dom abolition, France and Germany's slip into net outflow, the rise of Saudi Arabia, the maturation of Italy and the UAE as serious destinations - these are not isolated events. They are the visible surface of a structural shift.
For HNW and UHNW families shopping the world's prime markets in 2026, branded residences and residency strategy are no longer parallel conversations. They are the same conversation. The right property in the right jurisdiction does three jobs at once: lifestyle asset, balance-sheet investment, and the qualifying basis for a residency that the family can actually use.
At Brightwill, the projects we surface are selected with all three jobs in mind. Our portfolio - ORLA Dorchester in Dubai, Tierra Viva Lamborghini and Marea by Missoni on the Costa del Sol, Six Fisher Island in Miami, Banyan Tree Aegir in Phuket - sits at the intersection of branded real estate and the residency programs that matter most in 2026.
Discuss your residency and real estate strategy with our concierge team →