Report on a panel session at the IBA’s 31st Annual International Private Client Tax Conference, held on 3 March 2026

Session Co-chairs

Michael Rutili, Stephenson Harwood, London

Emilie Van Goidsenhoven, Tiberghien, Brussels

Panellists        

Robert Desax, Walder Wyss, Zürich

Kärt Anna Maire Kelder, Sorainen, Tallinn

Xavier Xivillé, Cuatrecasas, Barcelona

Reporter

Lorenzo Ferro, Chiomenti, Milan

Structure and format

The discussion was led by two co-chairs and structured as an open and interactive exchange with the panellists. The format enabled a dynamic interplay between jurisdictional insights, practical examples and thematic reflections, with contributions building organically rather than following a rigid sequence.

This facilitated a fluid discussion, moving seamlessly from high-level trends to concrete issues encountered in practice, while allowing the panellists to refine and add nuance to each other’s observations.

Main themes

The session focused on the evolving drivers of global mobility, with particular emphasis on the younger generation, composed of economically active individuals. Therefore, the discussion deliberately moved away from traditional narratives centred on passive wealth or the adoption of purely tax-driven relocation strategies and instead addressed individuals who generate value through professional or entrepreneurial activities.

At the outset, it was noted that ‘new wealth’ is increasingly linked to activity rather than passive ownership. In this context, mobility decisions are shaped by individuals who need to operate, build and scale businesses across jurisdictions, rather than simply to preserve wealth.

A central theme was the progressive shift away from tax-driven relocation towards a more holistic assessment of the opportunities offered by different jurisdictions. The panellists consistently observed that, particularly among younger generations, tax considerations, while still considered to be among the relevant factors at play, are rarely decisive in isolation. One speaker remarked that individuals today are often 'willing to pay taxes somewhere', provided that the overall environment, from a business, political and quality of life perspective, is coherent and supportive.

Indeed, individuals tend to assess jurisdictions through a broader lens, taking into account quality of life, personal safety, family considerations and alignment with their personal values. Younger generations, in particular, were described as being more anchored to certain social or personal ‘causes’ and, therefore, less inclined to relocate purely for tax reasons.

In this context, the notion of a ‘holistic offering’ emerged as a defining concept: relocation decisions increasingly reflect a combination of legal, economic and personal factors. As succinctly noted during the discussion, it is no longer simply a matter of 'paying less tax', but of finding an environment in which both personal and professional objectives can be pursued effectively.

Perspectives and debate

While there was broad consensus on the declining centrality of tax, the panellists offered complementary perspectives on what effectively drives mobility decisions in practice.

It was emphasised that individual circumstances remain key. For some, family considerations and personal security may outweigh any fiscal advantages. For others, the decisive factor lies in the ability to operate within a strong and relevant business ecosystem. In this respect, it was noted that jurisdictions are increasingly evaluated based on their perceived role as industry hubs, rather than solely on the attractiveness of their tax regimes.

The discussion also reflected a broader shift in behaviour: the traditional narrative of individuals relocating primarily to minimise their tax exposure appears to be less prevalent today. Instead, mobility decisions are increasingly aligned with professional opportunities and an individual’s long-term positioning.

Emerging jurisdictions, particularly in Eastern Europe (the example of Poland was provided), were highlighted as increasingly competitive in this context. These jurisdictions often combine favourable tax regimes with developing business ecosystems.

However, the panellists also raised questions regarding the clarity and long-term stability of such frameworks, as well as the impact of geopolitical factors. As one speaker pointed out, attractiveness ultimately depends not only on incentives, but also on the perceived reliability of the system over time.

Practical examples and case studies

A number of practical examples were used to illustrate the complexity of relocation decisions and the importance of adopting a holistic perspective.

One example involved early stage technology entrepreneurs relocating to the Baltic region, including founders from neighbouring jurisdictions. In these cases, the attractiveness of the destination depended on a combination of factors, including the applicable immigration rules, employment taxation and intellectual property regimes. The discussion emphasised that advisers should consider the complete business environment in a given jurisdiction, rather than focusing narrowly on just the tax incentives offered.

Another example put forward concerned a defence technology startup that was initially established in Switzerland. While Switzerland provided a favourable starting point, regulatory constraints (particularly in relation to export controls) ultimately limited the company’s ability to scale up the business. The business subsequently relocated to the United States. This example illustrated how sector-specific regulation may override tax considerations in determining the optimal location to conduct business activities.

Additional operational challenges were also discussed. As noted during the session, even seemingly basic issues, such as the ability to open a bank account, may become a significant obstacle in certain jurisdictions. These practical constraints, although often overlooked, can in practice determine whether a relocation strategy is viable.

Key challenges

The panel identified several recurring areas of risk in the context of international mobility.

A first area of concern relates to double tax treaties. It was noted that certain preferential regimes may not benefit from full treaty protection. For instance, questions were raised as to whether specific regimes, such as the so-called Beckham law regime in Spain, allow taxpayers to access treaty benefits, with there being indications that this may not always be the case. Divergences between jurisdictions, including in relation to newer regimes, such as the UK’s foreign income and gains (FIG) regime, contribute to uncertainty.

Timing issues were also highlighted as a critical risk factor. In particular, split-year treatment and the risks associated with returning to a jurisdiction too soon after relocation may lead to unexpected tax consequences. Practical examples from Switzerland and Belgium were used to demonstrate how insufficient planning in this respect may produce adverse outcomes.

Increased transparency due to the automatic exchange of information under the Organisation for Economic Co-operation and Development’s (OECD) Common Reporting Standard (CRS) was also emphasised. The growing availability of cross-border information significantly reduces the scope for inconsistencies and requires the careful alignment of reporting positions across jurisdictions.

Importantly, panellists stressed that an excessive focus on an individual’s tax position may lead to the neglect of relevant corporate risks. As noted during the discussion, there is often a tendency to 'put all the effort on the personal position and forget about the company'. Issues such as the creation of a permanent establishment or the determination of the place of effective management of companies, particularly in the asset management industry, may give rise to significant tax exposure if not properly addressed.

Opportunities and insights

Despite these challenges, the panel session also highlighted several positive developments.

Jurisdictions are increasingly developing integrated frameworks aimed at attracting mobile individuals and entrepreneurs, combining tax regimes with accessible immigration pathways and supportive business environments. This reflects a growing recognition that competitiveness requires a coordinated approach across multiple areas of law. Clarity and predictability were also identified as key success factors. Jurisdictions offering transparent and stable frameworks are likely to gain a competitive advantage, particularly where individuals are making long-term relocation decisions.

Implications in practice

From a practical standpoint, the session underscored the importance of adopting a comprehensive and forward-looking approach to mobility planning.

Advisers should move beyond purely tax-focused analysis and consider a wider range of factors, including immigration, regulatory and operational aspects. Early stage planning, ideally, and, to the extent possible, well before the relocation occurs, remains essential in order to anticipate potential challenges and structure the relocation effectively.

The discussion also highlighted the relevance of adopting a ‘lifecycle’ perspective. The factors that drive initial relocation decisions may differ significantly from those that become relevant during growth, scaling, exit or retirement. As noted during the session, planning for later stages, such as divestment, should ideally be considered from the outset.

Finally, ensuring consistency between personal and corporate structures is critical, particularly in cross-border scenarios involving active business operations.

New and surprising insights

One of the most notable insights was the extent to which tax considerations have become secondary for certain categories of mobile individuals. The willingness to prioritise stability, professional opportunities and personal values over tax efficiency reflects a significant shift away from traditional mobility patterns.

Equally noteworthy was the importance of practical constraints. Administrative barriers, such as banking access or onerous immigration processes, may ultimately determine the success or failure of a relocation strategy, despite being frequently underestimated during initial planning activities.

Overall impression and future outlook

Overall, the session provided a nuanced and practice-oriented perspective on global mobility, highlighting both the increasing sophistication of relocation strategies and the growing complexity of the underlying legal and regulatory framework.

Looking ahead, it is likely that jurisdictions will continue to compete not only through the applicable tax regimes, but also through their broader ability to offer stable, coherent and attractive ecosystems. At the same time, the increasing interaction between tax, regulatory and operational considerations will require a more integrated and proactive approach from both mobile individuals and their advisers.