Global Mobility of Ultra-High-Net-Worth Individuals, Second edition

• About STEP 7 Introduction 9Nicola SaccardoCharles Russell Speechlys Part I. Jurisdictions Australia 11Daniel ApplebySpeed and Stracey Lawyers Belgium 31Dominique De BieGerd D GoyvaertsTiberghien Brazil 49Alessandro Amadeu da FonsecaMattos Filho Canada 63Elie S RothRyan WolfeDavies Ward Phillips & Vineberg LLP Cayman Islands 91Daniel AltneuBedell Cristin China 113Sakura JiPeter NiZhong Lun Law Firm France 127Stéphanie AuférilArkwood SCPClaire BrissetAlta Avocat Germany 141Christian von OertzenPhilipp WindeknechtFlick Gocke Schaumburg Greece 155Elina FilippouNikos MaltezosDespina MouroutiZepos & Yannopoulos Guernsey 177Matt GuthrieOgier (Guernsey) LLP Hong Kong 187Clifford NgHilary TaiSanlie YeungZhong Lun Law Firm LLPIndia 199Kunal SavaniRishabh ShroffCyril Amarchand Mangaldas Italy 221Nicola SaccardoCharles Russell Speechlys Jersey 237Jonathan HughesOgier (Jersey) LLP Malta 247Rosanne BonniciRebecca DiaconoFenech & Fenech Advocates Mexico 261Samy Lazarov SchipperAna Sofía Ríos ArtigasMiguel Valle SalinasChevez Ruiz Zamarripa Monaco 275Xavier de SarrauCorinne RicciardellaGordon S Blair Law Offices Portugal 285Maria Inês AssisNuno Cunha BarnabéAbreu Advogados Singapore 309Terre ChuaWei Lun GanVikna RajahRajah & Tann Singapore LLP Spain 321Florentino CarreñoCuatrecasas Switzerland 337Guillaume GriselSchellenberg Wittmer United Arab Emirates 353Donatello PirloCarlo Stefano RotaStatura United Kingdom 373Dominic LawranceJames RibyKelvin TannerCharles Russell Speechlys United States 397Dean C BerryWilliam S SchaafCadwalader, Wickersham & Taft LLP Part II. General topics The succession law ramifications of relocation 423Richard FrimstonAndrew GodfreyRussell-Cooke LLP Relocation – planning to avoid the pitfalls of divorce 441Rachael BurtonMark HarperHughes Fowler CarruthersRelocation and works of art 455Ruth CornettChristie’s Fiscal nomads: the impact of relocation on CRS and DAC6 469Samantha MorganRMW Law LLPJohn RichesRMW Law LLP; Withers LLPNaomi SheltonRMW Law LLP Practical issues faced by trustees on relocation of trust-related parties 483Pedro GemalAnna StewardSequent About the authors About Globe Law and Business

The world is getting richer. According to Henley & Partners’ Centi-millionaires Report, as of mid-2023 there were some 28,420 centi-millionaires in the world, that is individuals whose assets exceed $100 mn. By now there are no doubt more. That number includes of course 2,350 billionaires. And let’s not forget the merely wealthy, UHNW individuals whose assets exceed $30 mn. Real estate agents Douglas Elliman [New York-based] and Knight Frank in London team up annually to produce a Wealth Report. The 2024 edition estimates the global number of UHNWIs at almost 600,000. That may be a tiny fraction of the world’s population, but is it still an awful lot of people.What has driven this explosion of wealth is in part asset inflation, especially of property, but is mainly the result of globalisation: of markets, of brands, of supply chains, and of consumer purchasing habits. With all that has come mobility of residency and nationality. The wealthy are, in effect, global citizens. Take the case of the Mittal family, owners of the world’s second-biggest producer of steel, Arcelor Mittal. The firm is headquartered in Luxembourg, but employs 100,000 people worldwide. The public record tells us that the founder and current Chairman, Lakshmi Mittal, was born an Indian citizen and has become a British national, at time of writing resident in the UK. Second-generation CEO Aditya Mittal was born in Indonesia, educated there and in England and the United States. He has Indian citizenship. Many such families, whose wealth derives ultimately from enterprises they control, will move across the world as the stages of family life dictate: educating their children at secondary schools in the UK, for example, and at elite universities in the United States. Add in multiple home ownership in multiple jurisdictions, and the need for highly-skilled professional advice is more pressing than ever.So the issue of this second edition of Global Mobility of Ultra-High-Net-Worth Individuals is well-timed. The volume divides usefully into two sections. In the first are 24 country profiles, across Europe, North and South America, the Middle East and Asia-Pacific. Each one is compiled by legal specialists in their fields. They cover in great detail critical aspects of residency across each jurisdiction and reveal the traps that await the unwary and unprepared. Do not assume, for instance, that the trusts or tax planning created in the United States will hold up under French law and against the challenges of the Direction Générale des Finances Publiques (DGFIP). Or that the Swiss laws on taxation are uniform: in that country’s robust tradition of devolved democracy, taxation is in part a matter for each canton. It may make a material difference whether you are based in Zurich or Zug.The second part of this volume is grouped by topic, and different national regimes are compared and contrasted as they affect the natural concerns of the wealthy. Thus succession is discussed at length, and the pros and cons of residence by varying jurisdiction. This is of primary importance to both family businesses and business families, whose current wealth is diversified across multiple asset classes. Numerous countries are now setting out their stalls to attract the UHNW population, while others, such as the current UK government, seem to be doing their level best to drive them away. This book is an excellent point at which to start assessing the available options, and will serve both practitioners and their clients alike.