In an increasingly complex global environment, high-net-worth individuals are rethinking how they structure their wealth, residency and long-term planning. Shifting tax regimes, geopolitical uncertainty and evolving mobility trends are all contributing to a more considered, strategic approach to global wealth. While jurisdictions such as the Middle East have remained highly attractive in recent years, we are also seeing some families reassessing their footprint and considering a return to more established centres such as London, drawn by its stability, legal framework and global connectivity.
Against this backdrop, Lisa Cornwell, Partner, Leader Private Clients and Family Offices, PwC Switzerland, shares her perspectives on how globally mobile families are navigating these changes and positioning themselves for the future.
1. Across your international client base, are you seeing any notable shifts in how high-net-worth individuals are positioning themselves in response to recent geopolitical uncertainty?
We don’t see any rushed decisions amongst our client base but rather an interest in exploring their options – whether that is moving assets or even a second residence/ (or secondary domicile). This optionality to move or to be able to move has been a trend for some time amongst the UHNW community.
2. To what extent are clients accelerating plans to establish additional bases in stable jurisdictions such as London, and what is typically driving those decisions?
There are many reasons families choose to establish an additional base – it might be driven by work or investments, by tax costs, by family considerations such as stability of a location – or something else entirely! We see locations such as Switzerland, Italy and Dubai remaining very interesting to our client base and as outlined above, this trend for optionality of residence has been something we have seen as important to UHNWs for some time already. Those who did not have a “back up” plan have certainly considered what their options are in the recent months.
3. The UK’s FIG regime has attracted considerable attention globally. How does it enhance the UK’s proposition for internationally mobile individuals compared to other established wealth centres?
The UK’s FIG regime attracts significant interest from internationally mobile individuals, especially Americans drawn to London’s global appeal and shared language. However, compared to competing (primarily) European jurisdictions, its four-year period is relatively short, the reporting requirements are more comprehensive, and the lack of a straightforward immigration route makes relocation more challenging.
4. For clients managing wealth across multiple jurisdictions, how important is the role of a stable legal and tax environment when deciding where to establish residency?
For UHNW clients managing wealth across multiple jurisdictions, a stable legal and tax environment is very important to UHNW families when choosing residency, as it provides predictability for complex private wealth matters. While no jurisdiction is perfect and other factors often influence decisions, countries perceived as constantly changing and/or offering poor tax-life balance tend to be less attractive. Additionally, changing residency often reflects a shift in lifestyle patterns rather than a complete break from previous locations, given the global nature of their assets and residences.
5. The UK’s remittance regime is often perceived as complex. In practice, how can it be structured effectively for clients with diversified international income and assets?
For new residents, the UK’s remittance regime is no longer an issue having been replaced by the “FIG” regime. Existing long-term residents who have previously claimed the remittance basis may consider to make use of the Temporary Repatriation Facility, which, for a modest tax charge removes the concern around the remittance basis therefore it offers greater flexibility and helps simplify their tax position moving forward.
6. How are globally mobile families currently approaching inheritance tax and succession planning when adding a UK dimension to their structures?
The UK’s inheritance tax rules are complex and we have recently had a seismic shift in how families need to think about their succession with changes from April 2025 shifting from a domicile- to a residence-based system. Now, individuals resident in the UK for ten of the past 20 years face inheritance tax on worldwide assets, with a ten-year “tail” after leaving, prompting many globally mobile families to reconsider their UK ties. This creates significant compliance challenges and makes long-term planning essential, impacting structure choices and the timing of succession planning.
7. Are you seeing any shifts in how international clients structure their property ownership in key global cities, and how does London fit within that broader strategy?
London remains a key focus for UHNW families’ property portfolios, valued for lifestyle, succession, and wealth strategy. However, the era of using offshore structures for UK property tax efficiency is over, leading many to simplify holdings. More globally though, privacy concerns are driving interest in how to protect confidentiality if possible when purchasing real estate, with families willing to accept additional tax and compliance costs for greater discretion.
8. For a client looking to establish a presence in the UK as part of a wider international footprint, what early tax and structuring decisions are most critical to get right?
Timing is crucial when establishing a UK presence. Key decisions should ideally be made before becoming UK resident or at the latest before FIG regime eligibility expires. It’s important to clarify if UK presence or tax residency is the goal, as UK residency rules are complex Early planning around the FIG regime, existing holding structures, and the control of these structures is essential to avoid unexpected tax issues. Immigration status also impacts tax and flexibility, so coordinated advice on tax, immigration, and structuring from the outset is vital. In short, early, integrated planning is key. In short, the earlier the conversation happens, the better!
Visit https://www.pwc.ch/en/services/private-wealth.html for more info on PwC private wealth services.
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