international wealth structuring

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