Four European jurisdictions changed the terms on which wealthy foreign residents are taxed inside about two years. None of the changes were coordinated. All of them moved in the same direction.
The four moves
| Jurisdiction | What changed | Effective |
|---|---|---|
| United Kingdom | Non-dom regime abolished, replaced by a four-year foreign income and gains regime | 6 April 2025 |
| Spain | Investor residence permit repealed by Organic Law 1/2025 | 3 April 2025 |
| Italy | Substitute tax for new residents raised from €100,000 to €200,000 to €300,000 | €300,000 from 1 January 2026 |
| Switzerland | Expenditure-based taxation retained federally, abolished in several cantons by popular vote | Zurich from January 2010, others since |
Repricing, not closing
Read individually, each change looks like a national decision with a national explanation. Spain framed its repeal as housing policy, supported by its own statistic that 94 of every 100 such visas were tied to real estate. Britain framed its reform as fairness. Italy simply raised a price. Switzerland’s cantons voted.
Read together, three of the four regimes still exist. What changed is their cost, their duration or who qualifies. Britain’s replacement grants full relief but only for four years and only to arrivals with a clean decade behind them. Italy’s regime still runs 15 years, at triple the entry price. The routes were narrowed rather than shut.
Three of the four regimes still exist. What changed is the cost, the duration and who qualifies.
Rich & Richer
Where the flow went
Capital that leaves one jurisdiction has to arrive somewhere. Singapore passed 2,000 single family offices while quadrupling its own entry threshold, which is the same pattern in the opposite hemisphere: recruit, then raise the bar.
That symmetry is the useful observation. Jurisdictions competing for mobile wealth are converging on a similar answer, which is to accept fewer, larger, more substantive arrivals rather than many small ones. The competition has not stopped. Its unit of measure changed.
What it implies for planning
Three things follow. Optionality across jurisdictions is worth more than optimisation within one. Fifteen-year commitments made under statutes amended twice in two years deserve scepticism. And structures built for a domicile test do not automatically work under a residence test, which is where the inheritance tax exposure tends to surface.
The direction of travel has been consistent enough for long enough that treating it as noise is now a choice. Families reviewing entity and estate arrangements against a residence-based world will find the structural considerations set out in this private client overview.
Frequently asked questions
Which European wealth tax regimes changed recently?
Britain abolished the non-dom regime on 6 April 2025, Spain repealed its investor residence permit on 3 April 2025, Italy raised its substitute tax to €300,000 for residence transferred from 1 January 2026, and several Swiss cantons have voted away expenditure-based taxation.
Is Europe closing to wealthy residents?
Not closing. Repricing. Most regimes still exist, but at higher cost, shorter duration or narrower eligibility than three years ago.
Which route was removed outright?
Spain’s investor residence permit, repealed by Organic Law 1/2025 with effect from 3 April 2025.
What is the common thread?
Domestic politics, particularly housing affordability, rather than coordinated international tax policy.