A Taxing Choice: Migration, Millionaires, and the Meaning of ‘Exodus’

As a tax adviser, I never thought that my key task on a given day recently would be to look up the meaning of ‘exodus’ in a dictionary to justify whether it had been applicable to use it in the context of taxpayers changing countries. I had an interview lined up later that day with a UK media outlet, which was challenging the use of the word ‘exodus’ to describe the net outflow of millionaires from Britain since Brexit.

It is clear that people are moving, and the wealthy, who travel anyway, will find it much easier to do so. If you have three homes, basing yourself out of one rather than another is a matter of choice and convenience. As the great economist John Maynard Keynes said “When the facts change, I change my mind. What do you do, sir?”

The facts have changed. People have changed their minds about where they want to live.

It’s never one thing. It may be the economy, it may be the quality of life, and for some of the countries people are leaving, it’s often the culmination of societal changes or just a perception that things don’t work as well as they used to. Then it’s time to start thinking of where to go. With that discussion, there’s always the question as to what the tax consequences may be, and for many people this will always be important. But it’s never the only thing.

Migration myths and misplaced blame

It pains me deeply to see the UK as the top of the list for net millionaire emigration in the 2025 edition of the Henley Private Wealth Migration Report. It is also painful to see that a government in power for not even a year is somehow blamed for a trend that has been increasing for five years or more. But remember that this is a net number. The UK has a really good tax regime for new arrivals, with all foreign income and gains not taxable for four years, making it very appealing to millionaires and above. For senior executives or bankers who may be rotating on three-year assignments, if they still exist in the numbers they did, that’s really attractive. But under the UK’s immigration sponsorship rules, unless there is an employer standing behind the move, there is no simple route to access this fiscal benefit.

The net millionaire exit is also explained by a reduction in those arriving. Other countries make it clear that they welcome people wanting to invest their capital, offering residence rights along with structured investment pathways. At the time of writing, the UK does not, having withdrawn a previous program in 2022, just when it would have been useful for EU nationals who were no longer able to move there under free movement. And, as US nationals look elsewhere, they are denied a simple route to invest millions of dollars into the UK economy that could be used for national priorities. The UK and London are very attractive to people who speak a similar language while they sit out a presidential term for whatever reason — as long as there is an easy route to move there.

Tax is never the only reason, but a tax change does make people question their whole relationship with the state and what they get for their tax money. And once they start looking, the places with clear and transparent tax systems, where states do not seek to ‘own’ their worldwide assets from day one, are the ones that are easiest to move to.

Beyond the tax rate: choosing where to belong

Since our report last year, Italy increased its flat tax from EUR 100,000 to EUR 200,000 in August 2024. Before that, its rates were the same as Greece’s, and for many of our clients who were selecting a residence program, our discussions revolved around which country they felt more at home in. Many families have their preferred vacation destination, which often runs in the family for generations. Those with longstanding ties to Italy tended to prefer the Italian flat tax program, while those with an affinity for Greece veered towards its golden visa program.

But Italy’s doubling of its flat tax was partially explained by seven years of inflation. And we don’t see that it has reduced demand for Italy as a place to live. People tend to compare it to Switzerland, where the flat taxes vary by canton but typically start at around CHF 250,000. Or Monaco, where there is no tax. Interestingly, many clients have looked at the combined housing and tax cost, and Italy can come out as less expensive than Monaco, even with the flat tax. One thing we didn’t see was people with their heart set on Italy deciding to move to Greece because it had a lower tax bill.

Practical matters like the availability of places in international schools also drive discussions, and this is often a factor in favor of the UAE, which is welcoming to all nationalities and cultures and has a whole infrastructure of international schools, constantly building new facilities. And it happens to have no income tax. Many people rule it out though because it’s so far from Europe or the USA, regardless of the tax benefits.

The term doesn’t matter but the trend does

So, what did I find? Yes, ‘Exodus’ is the book of the bible which described the mass departure of Israelites from Egypt. Nobody is suggesting that every millionaire or billionaire is leaving any country to the extent that the last one out should switch off the lights. The dictionary also says it’s any mass departure of people. Philosophically, is around 1% of a population really a ‘mass departure’? It depends on what agenda the newspaper wants to make a story out of.

The French statesman Jean-Baptiste Colbert said, “The art of taxation consists in so plucking the goose as to obtain the largest possible amount of feathers with the smallest possible amount of hissing.” There has been a lot of hissing since we published our report this time last year, and a distinct shortage of feathers obtained.

When people vote with their feet it is easy to look at what they have chosen. Then it’s a choice for the governments to listen — or not. Debating whether ‘exodus’ was exactly the right word to describe the situation misses the point.