LEX LEGAL | The new treasure map: politics and taxes are changing the fate of the great fortunes
Published by Lex Legal | 12/16/2025 | Click here to see the original content
By Juliana Bhering Cabral Palhares , founding partner of Bhering Cabral Advogados
The dynamics of global estate planning are undergoing rapid transformations. Countries that historically offered stability and predictability are revising their tax regimes , while others are moving to attract internationally mobile families. This scenario, marked by regulatory fragmentation, demands heightened attention from those who organize assets with a multi-generational horizon.
Several traditional centers have been promoting important changes. The United Kingdom revised the non-dom regime, impacting structures consolidated for decades. Italy signals adjustments to the flat tax that attracted high-income residents, and France cyclically debates the advisability of taxes on large fortunes. This set of movements demonstrates that some European jurisdictions are experiencing moments of regulatory uncertainty, and this directly affects decisions about tax residency and asset allocation.
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Meanwhile, other countries are strategically moving to offer environments conducive to the establishment of families and family offices. Hong Kong has set explicit targets for attracting wealth management structures. Singapore continues to consolidate its robust and technically sound regulatory ecosystem. In the United Arab Emirates , the combination of clear rules, operational agility, and competitive costs has attracted a growing influx of high-net-worth individuals. These destinations are strengthened by delivering something increasingly valued: stability, clarity, and a long-term vision.
This structural shift in the geography of wealth is reflected in the behavior of families themselves. Asset mobility is no longer an exception but has become part of the strategy. Tax changes in Norway have motivated significant migration to Switzerland , just as changes in the United Kingdom have led to the departure of high-income residents. In many cases, the decision to reposition structures occurs within a few months, especially when there is an immediate impact on estate planning or asset preservation.
One increasingly evident aspect of this process is how future generations approach their choices regarding residence and asset structure. Children of globalized families tend to adopt a pragmatic view, prioritizing environments that combine economic opportunities, regulatory security, and freedom of mobility . For this generation, territorial ties are no longer a fixed element, but an adjustable variable depending on whether the country proves—or ceases to prove—favorable over time. Jurisdictions that offer stability, efficiency, and openness tend to retain these families; those that signal uncertainty or excessive rigidity become less attractive.
In this context, estate planning is closer to the logic of asset allocation. Each jurisdiction fulfills a function, whether it be governance, investment, residence, or protection . This modularity allows families to continuously reassess where they are and where they want to be, without permanent commitment to a single structure or country. It is a more fluid, more technical approach, deeply adapted to contemporary reality.
Global regulatory fragmentation highlights that legislative stability remains a strategic asset. Jurisdictions that understand the importance of offering predictability tend to consolidate themselves as lasting hubs for family businesses. And, in the face of a generation that values mobility and rationality in choosing destinations, a country's ability to maintain institutional clarity will be increasingly crucial to its competitiveness in the international asset market.
