Italy tax planning for UHNWI: global wealth trends and opportunities in 2026

The sustained growth of Ultra High Net Worth Individuals is reshaping international investment, residency, and tax planning strategies. Here is what it means for high net worth individuals with Italian interests.

The global expansion of Ultra High Net Worth Individuals (UHNWI) — defined as individuals with a net worth exceeding USD 30 million — is accelerating the demand for sophisticated Italy tax planning for high net worth individuals. As geopolitical fragmentation intensifies and fiscal policies tighten across multiple jurisdictions, international mobility, jurisdictional diversification, and integrated tax risk management have become central priorities for wealthy families and their advisors.

1. UHNWI growth and the global concentration of wealth

In recent years, the global UHNWI population has surpassed 700,000 individuals, recording sustained growth even amid macroeconomic uncertainty and an increasingly selective fiscal environment. The United States remains the primary wealth creation hub; however, new growth areas are consolidating rapidly across Asia and the Middle East. Furthermore, this geographic redistribution of wealth is generating material implications for cross-border tax planning.

As a result, cross-border tax planning has evolved from a niche discipline into a core component of wealth management for globally mobile individuals. Key areas of focus include:

• Analysis of international tax treaties to optimise cross-border income flows
• Selection of tax-attractive jurisdictions for fiscal residency — such as Italy’s flat tax regime for new residents (Article 24-bis TUIR, EUR 300,000 annual substitute tax)
• Structuring international investments through holding companies and family office vehicles

2. Fiscal policy, geopolitics and international mobility of high net worth individuals

The tightening of fiscal policies across several major jurisdictions, combined with growing geopolitical fragmentation, is accelerating global mobility among high net worth individuals. Consequently, the selection of a fiscal domicile is no longer driven solely by tax rates, but by a broader combination of factors.

Moreover, a growing trend towards “multi-jurisdictionality” is emerging: individuals and families are increasingly distributing their residency, assets, and economic interests across multiple countries simultaneously. In this context, family offices play a central role in the integrated management of tax risk, international compliance, and wealth governance.

Several European and Middle Eastern jurisdictions are, in addition, establishing themselves as alternative hubs, driven by competitive tax regimes and high standards of living. Italy, in particular, offers a compelling combination of lifestyle, legal stability, and attractive tax programmes for internationally mobile individuals.

3. Italy tax planning for high net worth individuals: key opportunities

Italy offers a range of tax planning tools specifically designed for internationally mobile high net worth individuals. Therefore, for UHNWI considering Italian tax residency or with existing Italian interests, the following instruments deserve careful evaluation:

4. Strategic priorities for UHNWI in 2026

In light of the trends outlined above, high net worth individuals are increasingly reviewing their international wealth and tax planning strategies. Notably, the following areas require priority attention:

• Coordination between fiscal residency and asset location — ensuring that the jurisdictional mix of assets aligns with the individual’s tax residence profile
• Efficient use of holding and corporate structures — selecting the optimal vehicle for managing international investments and ownership chains
• Multi-jurisdictional succession planning — addressing the interaction between different inheritance regimes across countries of interest
• Ongoing monitoring of international regulatory changes — particularly in the areas of OECD minimum taxation, CFC rules, and bilateral treaty updates

Furthermore, a proactive and integrated approach allows high net worth individuals to capture opportunities arising from increased global mobility, while simultaneously mitigating fiscal and regulatory risks. In this respect, early engagement with specialist advisors — including through advance rulings with the relevant tax authorities — is strongly recommended.

How Studio BCZ can assist

Studio BCZ provides specialist Italy tax planning for high net worth individuals at every stage of the planning and compliance process. As a result, our team offers a fully integrated service covering:

• Preliminary assessment of feasibility and tax convenience
• Advance tax ruling (interpello) with the Italian Revenue Agency
• Italian income tax return preparation and filing
• Bespoke advisory on international tax structuring, holding vehicles, and succession planning