The era of taxing companies is giving way to the era of taxing wealth. That is the central argument of my latest article, “Why Private Wealth is the Next Tax Frontier”, published this month in Taxation — the LexisNexis/Tolley title that has been the United Kingdom’s leading journal for tax professionals for over a century. You can read the full piece here
The article sets out a simple thesis: as corporate tax bases erode and public finances tighten, governments across the OECD are quietly redirecting their attention from multinational profits to private capital — and the architecture being built to support that shift will, in time, be as significant for high-net-worth individuals as BEPS 2.0 has been for multinationals.
From corporate focus to private wealth
International tax reform has, until now, been a corporate story. The OECD’s Pillars 1 and 2, the global minimum rate, and the G7 compromise of June 2025 have all been aimed at the largest groups. But with public expenditure rising and global private assets under management approaching $145 trillion, the political logic has changed. Attention is moving towards private individuals — particularly those with cross-border assets, mobile lifestyles, and sophisticated structures.
This is not, in my view, a debate about whether people should relocate for tax reasons. That framing belongs to an older model of planning built around gaps and loopholes. What is emerging will demand something quite different: genuine economic substance, real transparency, and structures built to last.
Towards a possible “Pillar 3”
The Pillars 1 and 2 process showed that international coordination on tax — however imperfect — is achievable when revenue bases are under threat. A growing number of academics and policymakers are now discussing what a “Pillar 3” focused on private wealth might look like. The ideas under consideration include minimum standards for taxing wealth above defined thresholds, greater harmonisation of inheritance and gift rules, and coordinated measures to address the so-called “tax nomad”. Each raises serious legal and political difficulties, but the direction of travel is unmistakable: private wealth will be more closely monitored and more consistently taxed across jurisdictions.
Implications for internationally mobile clients
For families and individuals connected to the United States, the United Kingdom, GCC, Colombia, Ireland and Spain — the jurisdictions at the centre of my practice — these developments are already reshaping the planning landscape. Structures designed primarily for tax advantage are unlikely to stand the test of time. Future-proof planning will need to reflect real economic substance, anticipate the next round of compliance change, and adopt transparency as a starting position rather than a concession.
Spain’s Beckham Rule and Digital Nomad Visa remain in place, but recent political and media scrutiny shows how quickly favourable regimes can come under pressure. Similar questions are being asked across the European Union, and wealth taxes are once again on the political agenda in the United Kingdom and beyond.
This article reflects general developments in international tax policy and is not legal or tax advice. Clients with cross-border interests should seek tailored advice in each relevant jurisdiction and are welcome to contact Outline Chambers to proceed.