cross-border wealth planning – Paolo Gaeta & Associati International

Italy 2026: Why Global Wealth Is Choosing Italian Residency

Studio Gaeta International / June 3, 2026

A strategic guide to the €300,000 flat tax regime, luxury real estate and wealth structuring for international UHNWIs. Executive Summary Italy is projected to be one of the world’s leading beneficiaries of millionaire migration in 2026.From January 1, the flat tax for new residents rose to €300,000 — yet Italy remains one of Europe’smost competitive jurisdictions for international UHNWIs. This guide analyzes the new regime, the luxury real estate context, and the structural decisionsthat determine whether a relocation succeeds or fails. Introduction: A Silent Reallocation of Global Wealth A quiet but profound transformation is underway in the world of large private fortunes. According toHenley & Partners, 2026 is projected to deliver the largest migration of wealth on record, with as manyas 165,000 millionaires expected to relocate internationally, up from 142,000 in 2025 and 134,000 in 2024. This is no longer a marginal phenomenon. It has become the defining mechanism through which capital,talent and entrepreneurial opportunity are being reallocated among jurisdictions. For families with substantial international wealth, the question is no longer whether to consider a changeof residence, but where, how, and — most importantly — with what structure. Italy has emerged as one of the most credible answers to that question. And from January 1, 2026,the rules have changed in ways that every adviser to UHNWI families needs to understand. 165,000 Millionaires relocating globally in 2026 (forecast) 3,600 Net HNWI inflows to Italy in 2025 €300K New annual flat tax for Italian non-doms 1. The 2026 Italian Non-Dom Regime: What Has Changed, What Has Not The 2026 Budget Law introduced a material amendment to Article 24-bis of the Italian Income Tax Code,the cornerstone of Italy’s special tax regime for new residents. The New Numbers – Annual substitute tax on foreign-source income raised from €200,000 to €300,000 for the principal taxpayer. – Family member surcharge doubled from €25,000 to €50,000 per qualifying family member. – Maximum duration unchanged at 15 tax periods. – Grandfathering fully preserved for individuals who established Italian tax residency before January 1, 2026. What Has Not Changed — And Why It Matters Despite the higher headline figure, the architectural integrity of the regime remains intact. This is thecritical point that international advisers should communicate to their clients. No taxation on foreign-source income beyond the lump sum, regardless of amount. Full exemption from Italian wealth taxes on foreign real estate and foreign financial assets. Full exemption from Italian inheritance and gift tax on foreign-situs assets transferred to heirs during the regime. Waiver of foreign-asset reporting obligations for assets covered by the regime. Italian-source income continues to be taxed under ordinary rules. For a family with €5 million or more of recurring foreign-source income, an annual substitute tax of€300,000 may still represent an effective burden well below the top marginal rates prevailing acrossmost of Europe. The Strategic Read Italy has not retreated from the UHNWI market. It has done the opposite: it has explicitly positioneditself in the top tier of European wealth jurisdictions, alongside Switzerland’s cantonal forfait regimesand Monaco. The price of entry has risen — but so has the political stability and durability of the framework.The increase is best read as a sign of confidence: Italy expects the demand to remain, and it has chosento monetize that demand rather than restrict it. 2. Why the Timing Matters: A Window Created by Other Jurisdictions The relative attractiveness of Italy in 2026 is not only about what Italy offers. It is also about whatother jurisdictions have stopped offering. – The United Kingdom abolished its non-dom regime effective April 6, 2025. – Portugal replaced its Non-Habitual Resident regime with a substantially diluted successor program. – Several other European jurisdictions have tightened their preferential regimes under political pressure. Italy now stands as one of the few remaining major European economies that combines a stable, codified,long-duration preferential regime with the lifestyle, cultural depth and infrastructure that UHNWI families require. 3. The Luxury Real Estate Dimension: From Investment to Strategic Reserve Capital relocating to Italy is increasingly anchored to Italian real estate — and the nature of thatanchoring has changed. Market Data – Increase in high-end property purchase inquiries year-on-year. – Average ticket size rising significantly. – Strong demand originating from abroad, particularly the United States, United Kingdom, Germany and France. – More than half of properties above €5 million transacted off-market. – Rome, Tuscany and Milan increasingly prominent among UHNWI destinations. The Logic Has Shifted Luxury Italian real estate is no longer primarily understood as a rental-yield asset. It has become acapital preservation instrument — a tangible, scarce, irreplaceable store of value within a diversifiedUHNWI portfolio. Iconic villas, historic palazzi, lakefront estates and trophy properties are increasingly held in dedicatedholding structures designed to combine asset protection, succession planning and fiscal efficiency. This is precisely the intersection where our firm operates. 4. The Adviser’s Lens: What Foreign UHNWIs Actually Need International UHNWIs relocating to or investing in Italy typically require coordinated advice across fivedomains. The first mistake families make is to address them sequentially rather than in an integrated plan. Tax Residency Planning The flat-tax regime is not automatic. It requires that the individual has not been tax-resident in Italyfor at least nine of the ten preceding tax years, and the option must be formally exercised through theannual tax return. Asset Holding Structures Trusts, foundations, holding companies and family investment vehicles each have distinct tax, successionand governance consequences in the Italian context. Their interaction with Article 24-bis requires carefulnavigation. Real Estate Acquisition Structuring Whether the acquisition vehicle should be the individual, an Italian società semplice, a domestic or foreignSPV, or a trust structure depends on the family’s intended holding horizon, the use of the property,succession plans and the residence status of beneficiaries. Succession and Generational Governance The flat-tax regime offers a highly advantageous succession environment — but only if the family wealth isproperly characterized and the governance documentation is internally consistent. Compliance and Confidentiality Italy has rigorous anti-money-laundering and beneficial-ownership disclosure regimes. Discretion isachievable within the law — but only through structures designed

UAE Foundations: the Wealth Planning Tool Italian Clients Are Overlooking

In recent years, the United Arab Emirates have ceased to be perceived merely as a “business-friendly” jurisdiction. They are increasingly emerging as a legal laboratory of interest for international wealth planning. In this context, the UAE foundation deserves particular attention as a vehicle which, if properly structured, can offer robust governance and effective asset segregation.Since 2017, more than 2,200 foundations have been established across the three main UAE regimes — RAK ICC, ADGM and DIFC — with 848 new registrations recorded in 2025 alone. What is a UAE Foundation and how does it differ from a trust From a legal perspective, a RAK ICC foundation is a legal entity with its own separate legal personality, distinct from that of the founder and other involved parties. It is designed to hold and manage assets in accordance with the purposes set out in its charter and by-laws, within a long-term governance and succession framework. A foundation is not typically established to carry out commercial activities. The RAK ICC framework expressly provides that any such activities must be merely ancillary or incidental to its objectives. In practice, it can act as a central governance platform for family wealth, shareholdings, real estate, financial portfolios or philanthropic projects, without being confused with the underlying operating business. From an operational standpoint, the RAK ICC regime provides for: a minimum initial capital of USD 100 the appointment of a Registered Agent at least two Council Members the possibility to appoint a Guardian in certain cases a limited level of public disclosure restricted to essential registry data, with the remaining documentation kept confidential except where disclosure is required by competent authorities The 2025 RAK ICC Reforms: What Has Changed The amendments that came into force on 31 July 2025 represent a significant development. They move in the same direction as reforms already observed in the DIFC in 2024, confirming a broader trend toward convergence among UAE regimes and alignment with international private wealth planning standards. Enhanced cross-border protection (firewall provisions) RAK ICC has strengthened its firewall provisions: courts are not required to recognise or enforce foreign judgments that are inconsistent with the foundation regime. The same principle extends to founders, contributors, council members, guardians and qualified recipients. In particular, succession rights arising under foreign law in respect of assets of a living person are not recognised within the RAK ICC framework. Creditors: defined perimeter and three-year limitation period The new rules introduce a three-year limitation period to challenge the establishment of a foundation or the transfer of assets to it. More importantly, they clarify that, where claims are upheld, remedies are limited to the specific transferred asset — or its proceeds — and do not automatically affect the entire structure. This significantly improves clarity and manageability of risk exposure. Protection against coercion (duress) The amendments introduce explicit protection against requests, orders or pressures from parties acting under duress or pursuant to measures outside the competent jurisdiction. Foundation stakeholders are required to disregard demands or actions that are inconsistent with the powers conferred by the charter or by-laws. This provision reinforces the internal autonomy of the structure in distressed scenarios. Strengthened arbitration framework While RAK ICC continues to allow the choice between DIFC Courts and ADGM Courts, the 2025 reforms significantly enhance the role of arbitration. Arbitral tribunals are granted powers equivalent to those of courts in matters relating to the administration of the foundation, including representation of minors, unborn beneficiaries or unascertained persons. For complex family wealth structures, the advantage is not only procedural but also reputational. Clarification on assets held as trustee The 2025 reform further clarifies that assets held “on trust” by a foundation remain subject to the terms of the trust and do not form part of the foundation’s own assets. This is a technically important point for private trustee foundation structures. The UAE Tax Framework: Corporate Tax and Family Foundations The UAE federal tax framework has become more articulated and, in many respects, more transparent. The Federal Tax Authority has issued guidance on the taxation of Family Foundations, clarifying that a foundation may — subject to the conditions set out in Article 17(1) of the Corporate Tax Law — apply to be treated as an Unincorporated Partnership, i.e. as a fiscally transparent entity for UAE Corporate Tax purposes. If the application is approved, the foundation is not taxed at the entity level, and income, assets and liabilities are attributed to the beneficiaries in accordance with applicable rules. The main conditions include: the foundation must be established for identified or identifiable natural persons and/or public benefit entities its primary activity must consist of holding, investing, distributing or managing savings and investment assets it must not carry out activities that would constitute a commercial business if performed directly by an individual its principal purpose must not be the avoidance of Corporate Tax Foreign entities — including foundations, trusts or similar structures — with a presence or nexus in the UAE may also access the same treatment, subject to meeting the relevant requirements. The Italian Perspective: What Italian-Resident Clients Need to Consider This is the area where Italian clients must exercise particular care — and where the difference lies between a structure that is merely attractive on paper and one that is truly sustainable. Where the founder or beneficiaries of a UAE foundation are tax resident in Italy, a number of rules come into play which require an integrated analysis and cannot be overlooked: Tax monitoring (RW reporting): assets held through a foreign foundation may fall within reporting obligations, depending on the level of control and the nature of the underlying assets. IVAFE: the tax on foreign financial assets may apply, depending on how the foundation is classified under Italian law. Residence of founder and governing bodies: the location of decision-making functions may be relevant in determining the effective tax residence of the structure. Legislative Decree No. 139/2024: the recent reform of trust taxation in Italy introduces new criteria that, by analogy, may also influence the