Southern Europe is rapidly emerging as a serious contender for global wealth, as high-net-worth individuals from the United States increasingly explore residency-lined investment options. The institutions that serve them already are positioning. Milan finds itself at the centre of this transformation. “As an asset manager, I would send someone tomorrow.”
Long dismissed as a bureaucratic afterthought in the European wealth management landscape, Italy’s commercial capital has become a magnet for wealthy individuals seeking tax-friendly residence options without the regulatory burden or visibility of more traditional hubs like London, Geneva, or Luxembourg.
According to Jacopo Zamboni, head of the Swiss office at Henley & Partners, a firm specialized in residence and citizenship advisory, Milan is emerging as a top destination for wealthy individuals looking to secure residency through investment.
“It’s 100 percent a no-brainer for asset managers or wealth managers to start a satellite operation in southern Europe, especially Milan,” he told Investment Officer. “The demand for residency-linked investment structures - whether in funds, listed companies or real estate - is very high among Americans and Northern Europeans.”
Total applications for the Italy program are set to grow significantly this year, with the applications seen up to end April 2025 already 63 percent of way to matching all of 2024.
Once-in-a-generation opportunity for firms
Zamboni believes the shift creates a once-in-a-generation opportunity for firms willing to follow the money. “If I were a European asset manager, I’d place a senior colleague in Milan tomorrow,” he said.
Some are already doing just that. Swiss-based Julius Baer, through its Luxembourg subsidiary, received approval this year to open a branch in Milan aimed at serving Italy’s growing population of ultra-wealthy clients.
“We are excited to enter the Italian onshore market with our own local presence,” said Sonia Goessi, the bank’s head of Switzerland and Europe.
This month, private equity-giant Ares Management opened a Milan office as part of a broader strategic push to capture Italy’s surging demand for private market solutions. “It’s a unique moment to onboard clients you previously couldn’t reach,” Zamboni said.
New regime inspired by UK
Italy’s regime for new residents, introduced in 2017, allows wealthy individuals to pay a flat tax of 100,000 euro annually on foreign income, a system broadly modelled on the UK’s former non-dom policy, but with more flexibility. Investors can gain residency by making a qualifying investment, such as 500,000 euro in an Italian listed company. The only requirement: custody in Italy.
Zamboni called the regime “a very beautiful baby”, the product of what he sees as a smart policy merger. Italy took the UK’s old non-dom regime and the Swiss forfait system, and created the Italian substituted tax on foreign income.
“If you relocate to Italy, regardless of your nationality - even if you’re Italian - everything you earn abroad, we do not care, provided you pay a fixed amount of 100,000 euro each year.”
The result, he argued, is more flexible than Switzerland’s.
“Italy lets you continue working while paying a flat tax on foreign income,” he said. “Switzerland doesn’t. That makes Italy more attractive for active professionals, not just retirees.”
“Dual citizenship, once a luxury, is becoming the new American dream.”
Jacopo Zamboni, Henley & Partners
Enquiries for Italy’s residency programme more than doubled in 2024, and rose by a further 57 percent in the first quarter of this year alone, according to Henley & Partners. The sharpest growth has come from Americans, who now represent the largest nationality group enquiring about the scheme. Inquiries from the US jumped 53 percent last year and climbed another 72 percent in early 2025.
They’re not just reallocating capital; they’re rethinking personal exposure too. Peter J. Spiro, a professor at Temple University Law School and an expert on citizenship law, said the unpredictability of Donald Trump’s second term has made US citizenship feel less secure.
“Dual citizenship, once a luxury, is becoming the new American dream,” he said. “In an era of rising uncertainty, many are seeking not just the right to stay, but the right to leave.”
UK losing its edge
The UK, in particular, has been losing its striking edge. The country has sent an unambiguous message with its abolition of the non-dom regime: wealthy foreigners are no longer a policy priority. Labour leader Keir Starmer has pushed through measures removing inheritance tax breaks on overseas trusts, further accelerating the departure of long-term residents. The UK Treasury expects the changes to raise over four billion pounds, but at what cost to its financial sector remains unclear.
Several top London figures are eyeing or already making the move to Milan, with Financial News reporting a wave of relocations this month. Among them is Richard Gnodde, vice-chair of Goldman Sachs, who is reportedly heading to Italy. He’s not alone: CVC co-founder Rolly van Rappard is said to be considering a move, following Cinven’s Soren Christensen and Astorg CIO François de Mitry, who, according to Bloomberg, has already relocated.
“We’re advising hedge fund founders, tech entrepreneurs, and family offices who are all looking for a Plan B,” Zamboni said. “Many won’t physically move, but they want the option. That option now comes with residency rights, tax certainty, and in some cases even political stability, something the UK can no longer guarantee.”
Indeed, most of the movement is not full relocation. Only 5 to 10 percent of clients actually move. “The rest are seeking what we call residence and citizenship planning. Think of it as personal geographic diversification, just like portfolio diversification. It’s not about escaping tax; it’s about reducing geopolitical exposure.”
Henley & Partners will publish its full migration forecast for 2025 in June. Early indications suggest a deepening split within Europe, with data pointing to net millionaire outflows from major economies like Germany, France, and Spain, while Italy and Switzerland are on track to post significant gains.
Benelux has work to do
Italy is not alone. Greece has introduced a near-identical flat tax system, charging 100,000 euro annually on foreign income for new residents. Portugal and Spain have long offered “golden visas,” though Spain recently scrapped its programme in the face of political backlash. Latvia too is gaining traction among ultra-high-net-worth individuals (UHNWIs) with its low-cost residency options and real estate affordability.
In contrast, Luxembourg, a titan of financial services in the Benelux, has seemingly missed the trend.
“They’re excellent on custody and fund infrastructure,” said Zamboni, “but their investment migration path requires physical relocation. For most clients, that’s a dealbreaker. They want optionality, not obligation.”
The same can be said for the Netherlands and Belgium, where residency rules are tied to genuine relocation and tax authorities are often perceived as aggressive. While both countries remain essential hubs for institutional capital, their appeal for personal wealth planning is waning.
Opportunity cost
“We’ve seen very little uptake in the Benelux for alternative residency programmes,” Zamboni noted. “That’s an opportunity cost.”
That matters, because the flight of UK-based wealth isn’t just about where individuals live. It’s about where they custody their assets, where they buy funds, and which legal jurisdictions they trust. With hundreds of billions in mobile capital now searching for a new home, asset managers and private banks across Europe are racing to adapt.
London, Zurich, and Luxembourg will not disappear. Their infrastructure, talent base, and networks are formidable. But they will face rising competition from southern capitals once written off as peripheral.
“Milan won’t replace London,” Zamboni conceded. “But it’s closing the gap. For many, especially Americans, it’s now the more attractive choice.”