Relocating abroad is one of the most financially complex decisions a high-net-worth individual can make.
Tax residency changes, pension transfers, cross-border estate planning and banking access all require expert coordination.
With a record 142,000 millionaires relocating internationally in 2025, the financial stakes of poor planning have never been higher.
Why are record numbers of wealthy individuals relocating in 2025?
Wealth migration has reached historic levels. A structural shift is underway in how high-net-worth individuals choose their country of residence.
142,000: the number of millionaires who relocated internationally in 2025, according to Henley & Partners’ Private Wealth Migration Report. This is the highest figure ever recorded.
The primary motivations are clear: favorable tax regimes, lifestyle appeal, active investment migration programs and access to greater opportunity. The UK recorded the largest net outflow, at approximately 16,500 millionaires. The UAE, United States, Switzerland, Italy, Portugal and Singapore were the principal destinations for incoming wealth.
The population of individuals worth at least $100 million grew 4.2% globally. For the first time, this group surpassed 100,000 people, according to Knight Frank’s Wealth Report 2026. As wealth grows, so does the incentive to protect it through strategic relocation.
Governments are responding. Several jurisdictions have introduced or expanded wealth taxes targeting high-net-worth residents. This is accelerating departure from certain markets and intensifying competition among destination countries.
What are the tax implications of moving abroad as an HNWI?
Tax is the most complex dimension of expat financial planning. Getting it wrong creates double liability, penalties and reputational risk.
|
Tax area |
Key risk |
Planning approach |
|
Tax residency |
Dual residency can trigger double taxation |
Tax treaty analysis before departure |
|
Exit tax |
Unrealised gains may be taxed upon departure |
Pre-departure portfolio restructuring |
|
Foreign income |
Worldwide vs territorial taxation varies by country |
Tax residency selection strategy |
|
Inheritance / estate |
Assets in multiple jurisdictions face multiple regimes |
International estate structuring |
|
Pension drawdown |
Taxation varies by country of residence |
Qualified transfer and jurisdiction review |
Most countries determine tax residency by physical presence. Common thresholds are 183 days per year. But several jurisdictions apply economic or social ties tests that can override the physical presence rule.
Double Taxation Treaties (DTTs) between countries provide a framework for resolving conflicts. However, interpretation varies. Advisors in both the destination country and the home country must be engaged before any move.
Exit taxes are particularly relevant for HNWI individuals. The United States taxes unrealised gains on departure for citizens with net worth above $2 million. France and Germany apply similar rules. Pre-departure planning is essential.
Professional Insight from Hexagone Group
Hexagone Group advises clients to begin tax planning at least 12 months before a planned relocation. The interaction between exit taxes, new domicile rules and pension status can materially affect net wealth. Hexagone Group recommends coordinating legal, tax and financial advisors across both jurisdictions simultaneously.
How does relocating affect your pension and retirement planning?
Pension planning is one of the most under-estimated challenges in expat financial planning. Complications arise quickly when crossing borders.
- Portability: most national pension systems do not allow direct transfer abroad. Qualifying Recognised Overseas Pension Schemes (QROPS) allow transfers to overseas vehicles, but rules vary by destination country.
- Taxation on drawdown: pension income is taxed differently in each country. A pension drawn in the UAE may be entirely tax-free. The same pension drawn in France or Germany attracts income tax at local rates.
- Contributions abroad: making pension contributions while resident abroad can trigger complex tax treatment. Some countries offer no tax relief on overseas contributions.
- State pension entitlement: contribution years in one country may not transfer to another. Totalization agreements between certain countries allow combination of records.
- Currency risk: holding a pension in one currency while spending in another creates ongoing foreign exchange exposure. This exposure compounds over a long retirement.
- Estate treatment: some pension structures pass outside the estate on death. Others attract inheritance tax. This varies by country and pension type.
A complete pension review should precede any international relocation. Restructuring after the move is almost always more costly than planning before it.
What banking and investment challenges do expats face?
Banking access is one of the most immediate practical challenges for newly relocated HNWI individuals.
Establishing international banking relationships before departure reduces these risks significantly.
Professional Insight from Hexagone Group
Hexagone Group’s advisory team recommends that HNWI clients consolidate their banking and investment custody early in the relocation process. The firm guides clients through custodian selection, account structure and regulatory compliance across jurisdictions. Hexagone Group suggests establishing a banking relationship that spans both home and destination countries before the move.
How should estate planning adapt when crossing borders?
Estate planning becomes substantially more complex for internationally mobile families. Assets held in multiple jurisdictions can be subject to multiple inheritance regimes simultaneously.
“Governments are increasingly targeting high-net-worth individuals through wealth taxes as private wealth grows faster than economies.” — Knight Frank, The Wealth Report 2026
This trend underscores why cross-border estate planning is not a one-time exercise. It requires ongoing review as legislation changes.
Several jurisdictions apply inheritance tax based on domicile, not residency. Domicile is a distinct legal concept. An individual can be tax-resident in one country while remaining domiciled in another. Each situation triggers different estate tax rules.
Wills must be reviewed for cross-border validity. A will valid in one jurisdiction may not be recognised in another. Many countries require locally-drafted wills for assets held within their borders.
Trusts, holding companies and family foundations can all serve as structuring tools for international estate planning. The appropriate vehicle depends on the jurisdictions involved, the nature of the assets and the family’s long-term goals.
What does a structured expat financial plan look like in practice?
A structured approach covers six simultaneous areas. Sequential planning creates gaps; integrated planning prevents them.
The planning covers six areas simultaneously: tax residency strategy, pre-departure portfolio review, pension transfer, banking setup in the new country, estate restructuring and compliance reporting.
Oliver Wyman’s 2026 wealth management research identifies tax integration and holistic advice as the critical differentiators for HNWI clients. In Europe, leading wealth managers now adopt a family office model integrating financial planning, estate planning and multi-generational wealth protection. This model is increasingly the standard for internationally mobile families.
The timeline matters. Planning that begins 18 months before a relocation allows time for proper structuring. Planning that begins after arrival is remediation, which is always more costly and more disruptive.
