Where the wealthy move themselves, their companies and trusts

Nobody pays to leave a place they could stay in for free. And yet the wealthy do it constantly — writing large cheques for the privilege of walking out the door.

A German founder pays tax on a company sale that never happened. A Norwegian shipping heir moves to Lucerne to dodge a wealth tax smaller than one good year's return. An American hands back the most powerful passport on Earth and pays a fee for the stamp. None of them is fleeing in the night. They are doing arithmetic, out loud, with lawyers in the room.

Because the sunny brochures about zero-tax islands leave out the important half. Arriving is the easy part. Leaving is where the money is — and a growing list of rich countries now charges an exit tax on the way out, on gains you may never have cashed.

This is a map of both halves. First, what it actually costs to leave, country by country. Then, the ten places the wealthy are moving to — and not just themselves, but the two things that matter more than a suntan: the holding company and the family trust.

Part one — leaving is the expensive part

America: the $450 goodbye is not the real bill

Only two countries on Earth tax their citizens on worldwide income no matter where they live: the United States and Eritrea. An American who moves to Dubai still files with the IRS, forever. Add FATCA — the law that turns every foreign bank into an IRS informant and gets US clients' accounts quietly refused abroad — and lifetime dual-filing with five-figure accountancy bills, and renunciation stops looking radical. It starts looking like housekeeping.

In 2026 the US State Department cut the fee to renounce citizenship by roughly 80 per cent, from $2,350 back to $450 — a change forced by six years of litigation, effective 13 April 2026. But the fee was never the real cost. The real cost is the exit tax. If you are a covered expatriate — net worth of $2,000,000 or more (a threshold frozen since 2008 and never indexed, so it quietly catches more people every year), or high average past tax, or unable to certify five clean years of filing — the IRS treats you as having sold everything you own the day before you leave, at market value, and taxes the gain. Only the first $910,000 of gain (2026) is exempt.

And there is a new sting in the tail. From 2025 the long-dormant Section 2801 regime went live: it taxes US heirs 40 per cent on gifts or bequests they later receive from someone who renounced as a covered expatriate. The enforcement form debuted in December 2025, seventeen years after the law passed. Renouncing badly does not just cost you — it can cost your children.

The volumes tell the story. US renunciations hit an all-time record of 6,705 in 2020, and rebounded to 4,819 in 2024 — up 48 per cent in a single year. The queue at the consulate is now the binding constraint.

Germany: taxed on money you never made

Germany's Wegzugsteuer — the exit tax under Section 6 of the Foreign Tax Act — is the purest "dry income" trap in the developed world. The day you stop being German-tax-resident, the state pretends you sold your company shares at full market value and taxes the unrealised gain. Nothing was sold. No cash changed hands. You owe roughly 28.5 per cent of a paper profit anyway — the 45 per cent top rate applied to the 60 per cent taxable portion, plus the solidarity surcharge. It bites anyone who held at least 1 per cent of a company and was German-resident for seven of the last twelve years.

This is exactly why German founders leave before the run-up, not after. Leave while the company is still small and the deemed gain is small; leave the year before a sale and you owe a fortune on money you have not received. The 2022 ATAD reform removed the old open-ended, interest-free EU deferral and replaced it with payment over seven annual instalments — some relief, but the bill still lands. And from 1 January 2025 the net widened sharply: it now catches ordinary investment-fund and ETF holdings held privately — any single position worth €500,000, or a 1 per cent stake. A regime built for tycoons now reaches the merely comfortable.

Norway: when the billionaires simply left

Norway runs a roughly 1.1 per cent annual wealth tax and, since 2022, a hardened exit tax — 37.84 per cent on latent share gains above a NOK 3,000,000 allowance, now with a firm twelve-year payment deadline and a dividend clawback. But it was the wealth tax, not the exit tax, that emptied the room. More than 30 of Norway's richest people emigrated in 2022 alone — more than in the previous thirteen years combined — and by 2024 around 300 wealthy Norwegians had gone. Most went to Switzerland. When the annual levy on your net worth exceeds what a cautious portfolio yields, you are being taxed on capital, not income — and capital gets on a plane.

The exit-tax league table

The mechanism differs; the direction of travel does not. Here is what leaving costs, in the countries most likely to be someone's point of departure.

Country	The exit mechanism	What it costs to leave
USA	Deemed sale for "covered expatriates" (IRC 877A)	First $910k of gain (2026) exempt, then CGT on the rest; a $450 renunciation fee; plus 40% on later gifts to US heirs
Germany	Wegzugsteuer — deemed sale of 1%+ stakes; now funds & ETFs over €500k	~28.5% of the paper gain, no sale, no cash; over 7 annual instalments
Norway	Exit tax on latent gains, plus the ~1.1% wealth tax that did the real damage	37.84% above a NOK 3M allowance; 12-year deadline
France	Exit tax (Art. 167 bis) on latent gains over €800k after 6 of 10 years	31.4%, rising to ~34–35% with the high-income surcharge
Canada	Departure tax — deemed disposition of most property	~24–27% of the gain; deferrable indefinitely with security
Australia	CGT event I1 — deemed disposal of foreign assets	Up to 47% — or elect to stay in the Australian net and defer
Denmark	Fraflytterskat — shares over DKK 100k, 7-of-10-year test	27–42%, but an interest-free deferral avoids the cash crunch
Spain	Exit tax (Art. 95 bis) for large shareholders	19–30%, on portfolios over €4M or a 25%+ stake over €1M
Netherlands	Conserverende aanslag — a "protective assessment" on a 5%+ stake	24.5–31%, parked interest-free until an actual sale

And Britain deserves a footnote, because it did something subtler. The UK has no exit tax — but in April 2025 it abolished the non-dom regime and pulled long-term residents' worldwide estates into 40 per cent inheritance tax. You do not need an exit tax to trigger an exodus; you just need to make staying more expensive than leaving. The millionaires left.

The lesson is uniform: price the departure before you choose the destination. Now, the destinations.

Part two — the package: you, the holding company, the trust

Here is where amateurs and professionals part company. Relocating well is not one move; it is three.

**Where you become tax-resident** — the personal-tax question, and the one everyone fixates on. We ranked that separately, in 10 low-tax countries for an exit, a portfolio or a trading book.
**Where the holding or management company sits** — because your investment income, your intellectual property and your next company usually flow through an entity, and that entity has its own tax home.
**Where the family trust or foundation lives** — the vehicle that decides succession, forced-heirship protection, and what your heirs actually inherit intact.

Sometimes one country does all three. Usually you split them — a Monaco address, a Luxembourg holding company, a Jersey trust — because almost nowhere is best at all three at once.

One reality check before the list, because it is the honest part the offshore industry skips: since the Common Reporting Standard, none of this is secret. Your banks report your accounts to your country of tax residence automatically. What these structures buy you is a lower rate, cleaner succession and genuine asset protection — not invisibility. Anyone selling you the second thing is selling you an audit. (There is exactly one exception, and it is at number ten.)

1. United Arab Emirates — the whole package under one desert roof

The cleanest slate on Earth: 0 per cent on personal income, capital gains and private crypto, with no personal tax return even existing to file. For a post-renunciation American or an ex-German founder who has already paid the exit tax, the UAE offers zero going-forward drag on worldwide investment income.

You: residence via the ten-year Golden Visa (AED 2M / ~US$545k in property or an approved fund) or a free-zone company plus investor visa for US$5–15k. Tax-residency certificate at 183 days, or 90 with a home and real ties.
The holdco: a DIFC or ADGM free-zone holding company pays 0 per cent on qualifying income; there is no controlled-foreign-company regime, and 0 per cent personal tax on the distributions it pays you.
The trust: a DIFC or ADGM common-law foundation — an English-law firewall against forced heirship, no public beneficiary register, and a "family foundation" transparency election. The Gulf's fastest-rising answer to a Liechtenstein Stiftung.

The catch: you must build real substance and real presence, or your old country's exit and CFC rules will argue you never truly left. The free-zone 0 per cent is a narrow gate that snaps to 9 per cent if you breach it, and for a US person none of it is clean until you have actually renounced.

2. Switzerland — the capped bill, with Liechtenstein next door

Switzerland's forfait fiscal taxes your deemed annual expenditure, not your worldwide income — so an enormous global income can settle into a fixed, predictable bill. And private capital gains on securities are tax-free for everyone in Switzerland anyway. This is where Norway's exiles went.

You: negotiate a lump-sum ruling canton by canton before you arrive (Vaud, Valais, Geneva, Ticino, Zug). The effective minimum is typically CHF 150,000–400,000+, and you may not work or run a business in Switzerland.
The holdco: a participation-deduction holding in a low-tax canton pays near-nil on qualifying dividends and share-sale gains — Zug around 11.8 per cent, and Lucerne now edging it out as the cheapest.
The trust: Switzerland has no native private foundation for this, so you pair it with a Liechtenstein Stiftung thirty minutes across the Rhine (see number nine).

The catch: the fixed floor only pays off on very large income, you cannot work in Switzerland, and five cantons — Zurich among them — have abolished the deal. The Alpine havens, ranked by how much they make you suffer.

3. Singapore — no capital gains, and a family office to match

Asia's rule-of-law hub: no capital gains tax at all, foreign income generally untaxed unless remitted, blue-chip banking and the strongest passport for onward mobility.

You: tax residency at 183 days. Direct investor permanent residency is an eight-figure commitment; the sane path in is an Employment Pass or EntrePass tied to a real, funded Singapore company.
The holdco: a Singapore holding company — no CGT, a foreign-dividend exemption, tax-free one-tier dividends and more than ninety treaties.
The trust: a Singapore trust holding a fund under the 13O (S$20M) or 13U (S$50M) family-office incentive gives 0 per cent on qualifying income — if you genuinely staff an office there.

The catch: from 2025 the family-office incentives demand real substance — resident investment staff, local spend, minimum local investment. Active trading is taxed up to 24 per cent, and there is no Singapore passport without renouncing your others.

4. Italy — one flat fee for unlimited foreign income

Italy's neo-residenti regime is the boldest offer in Europe: a single fixed substitute tax covers all your foreign income and gains, no matter how large, for up to fifteen years.

You: the flat fee is now €300,000 a year for anyone moving from 1 January 2026 (those who arrived by end-2025 are grandfathered at €200,000), plus €50,000 per family member. Open to anyone not Italian-resident for nine of the last ten years. Italy's flat tax, in full.
The holdco: keep it outside Italy — an Italian company pays around 28 per cent. Route through a Luxembourg SOPARFI or a UAE free-zone entity. The flat tax shields you, the individual; it does nothing for a company's own tax bill.
The trust: use a foreign trust (Jersey, New Zealand) — the flat tax shields the resident beneficiary's foreign income, but Italy taxes distributions from low-tax jurisdictions and looks through sham trusts, so build it cleanly.

The catch: at €300k the fee only makes sense above roughly €1.5–2M of annual foreign income, and a founder's "qualified" stake sold in the first five years is carved out and taxed at 26 per cent — so it is a weak fit if your plan is an immediate exit.

5. Monaco — 0 per cent, and the rent is the tax

Zero tax on income, gains, dividends, wealth and direct-line inheritance for non-French residents. No lump sum, no annual return — just prestige and proximity to the EU core.

You: prove means with a bank deposit (typically €500,000+) at an approved Monaco bank, hold housing at roughly €52,000 per square metre (or rent), and pass a clean-record check.
The holdco and trust: do not site either in Monaco — companies with over 25 per cent non-Monaco revenue pay 25 per cent, and Monaco recognises trusts only awkwardly. Pair the address with a Luxembourg holdco and a Jersey or Guernsey trust.

The catch: French nationals are excluded from the deal entirely, and Monaco's astronomical, perpetual housing cost is the real tax. You pay it every month you stay.

6. Cayman Islands — control and privacy, not a tax trick

Zero Cayman income, capital-gains or estate tax — but the real product here is control. Cayman writes the strongest founder-control and privacy statutes in the offshore world.

The structure: a STAR trust (perpetual; beneficiaries have no right to information and no standing to sue — only an appointed enforcer does) or an ownerless Foundation Company. The classic pattern has the STAR trust own a private trust company that acts as trustee for the family's other trusts, with a Cayman exempted company under it holding the group's shares tax-neutrally.

The catch — read it twice: this is a governance and privacy tool, not a tax shelter. CRS reporting and economic-substance rules apply, US persons still hit grantor and throwback tax, and a (non-public) beneficial-ownership register exists. It buys perpetual control and confidentiality from co-beneficiaries and the public — not from tax authorities.

7. Portugal — the cheap EU foothold with a crypto quirk

The affordable way into the EU, with one genuine edge: crypto held 365 days or more is tax-free for every Portuguese resident.

You: the inexpensive D7 visa needs roughly €11,000 a year of income plus real presence; the Golden Visa now takes about €500,000 into a qualifying fund (the property route is closed) with only around seven days a year in Portugal.
The holdco and trust: keep both out of Portugal — corporate tax runs about 31.5 per cent all-in, trusts are not recognised, and distributions are taxed at 28 per cent. Pair with a Luxembourg or UAE holdco and a foreign trust.

The catch: the broad NHR regime is dead (closed 2025); its replacement, IFICI, is deliberately narrow — scientists, R&D and certified start-ups only. The real edge now is the crypto rule and the eventual EU passport, not a blanket shield.

8. Andorra — single digits in the Pyrenees

A maximum 10 per cent on all income, no wealth, inheritance or gift tax, and only around 90 days a year on the passive route.

You: passive residency now requires a €1,000,000 investment in Andorran assets (doubled under the 2026 reform), including a €50,000 non-refundable state fee, plus roughly 90 days on-island in Andorra.
The holdco: an Andorran company caps at 10 per cent — a genuinely low onshore rate, though without EU membership or a broad treaty network.
The trust: Andorra is civil-law and does not recognise trusts — anyone pitching an "Andorran trust" is mistaken; the domestic vehicle is a private-interest foundation.

The catch: the passive-residency price just doubled to €1M, it sits outside the EU, and crypto is taxed at 10 per cent, not zero.

9. Liechtenstein — the foundation that owns itself

The classic Continental dynasty vehicle. A Stiftung is a legally ownerless entity: it holds the wealth, so no person does — which ring-fences assets from creditors and forced-heirship claims and locks in succession across generations, inside an EEA state with no inheritance, gift, estate or exit tax.

The structure: a private-benefit foundation with a minimum CHF 30,000 endowment, kept off the public register as a "deposited" foundation, with founder-dictated distribution rules. A Liechtenstein company beneath it pays a flat 12.5 per cent, usually less after the participation exemption and the notional-equity deduction.

The catch: full CRS reporting means the founder, board, protector and beneficiaries are all disclosed to their home tax authorities — and keep your reserved powers modest, or your home country looks straight through the foundation as transparent. Forced-heirship claims can still claw back endowments made too close to death.

10. United States — the onshore "haven" that does not do CRS

The irony to end on. For non-American families, South Dakota, Nevada, Delaware and Wyoming offer perpetual dynasty trusts, self-settled asset protection, sealed court records — and, uniquely, confidentiality from home tax authorities, because the United States never joined the Common Reporting Standard. FATCA makes the world report to America; America reports almost nothing back.

The structure: you usually do not move to the US — becoming US-resident triggers worldwide tax and 40 per cent estate exposure. You site the structure there and live elsewhere: a South Dakota perpetual dynasty trust (permanent sealing of records) or a Nevada asset-protection trust, with a US LLC beneath it in a no-income-tax state holding the investments.

The catch: for non-US families the draw is secrecy and stability, not tax — and US-situs assets still face 40 per cent estate tax unless carefully engineered around. This is the one place on the list where confidentiality survives, which is precisely why the post-Pandora-Papers money keeps arriving.

The vehicles behind the vehicles

Five structures worth knowing that sit beneath the jurisdictions above:

Luxembourg SOPARFI — Europe's default holding company: a 100 per cent participation exemption on qualifying dividends and share-sale gains, full EU-directive access, the deepest fund ecosystem on the continent. The holdco you pair with an Italy, Monaco or Portugal residence.
Jersey, Guernsey and the Isle of Man trusts — the blue-chip, transparency-compliant offshore trust: mature "firewall" law that defeats forced heirship, 0 per cent local tax on foreign assets, respectability over secrecy.
Malta — a 35 per cent headline that collapses to about 5 per cent via the shareholder refund, plus a 0 per cent participation exemption — one of the EU's lowest effective holdco rates, if you can stomach the two-company structure and the banking friction.
Cook Islands and Nevis — the global gold standard for creditor deterrence: a US judgment is not recognised, the clock to challenge a transfer runs out in one to two years, and a Nevis creditor must post a bond just to start. Zero tax benefit; pure asset protection, and only for the solvent planning ahead of trouble.
Private Placement Life Insurance — not a place but a wrapper: it turns highly-taxed fund income into tax-deferred growth and a tax-free death benefit, provided an independent manager runs the money and you never touch the wheel. It needs a seven-figure premium and real net worth.

The three things that quietly kill most "offshore" magic

Before anyone sells you a structure, weigh it against the three forces that have gutted the old playbook:

CRS. Automatic bank reporting to your country of tax residence. The safe assumption is now that the tax office already knows.
The US grantor and throwback rules. If you are a US person, a foreign trust does not save you — the income is taxed to you, and deferred distributions are punished. American exposure follows the person, not the passport.
Substance and CFC rules. A paper company with no staff and no office is ignored, and its income is taxed back to you at home. Substance is no longer optional; it is the price of the benefit being real.

The verdict

If you are American, renounce only with your eyes open: the exit tax is paid once, but Section 2801 can follow the gift to your heirs — and the only route to roughly 0 per cent that does not require handing back the passport is Puerto Rico, in the companion piece.

If you are a German or European founder, the single most valuable decision is timing: leave before the valuation, not after, and model the exit tax as a real, dated cost — because it is.

And for almost everyone, the winning move is not to find one perfect country but to split the package: live where the personal rate is low and the life is good, hold through a Luxembourg or UAE company, and settle succession in a Jersey, Liechtenstein or South Dakota structure. The UAE is the rare place that does all three under one roof; most people assemble it from parts.

Every rich country will let you go. The only questions are what the door costs — and whether you paid it once, deliberately, on your terms, or kept paying the old country forever on theirs.