Globally mobile individuals with alternative and multiple residencies and citizenships, like Ultra-High-Net-Worth Individuals (UHNWI) including their family offices and wealth structures (trusts, private and charitable foundations) are more and more in the forefront of the Global Tax Agenda, together with Multinational Enterprises, Investment, Wealth and Philanthropy Hubs. Several jurisdictions in Asia-Pacific, Europe and the Middle East actively attract mobile individuals (UHNWI) with tax benefits through their Golden Visa, Family Office, Citizenship and Residence by Investment Programs and their lump sum, remittance base, territorial and low- or no tax systems and thereby actively apply their fiscal sovereignty and boost international tax competition. In contrast, high-tax countries rather restrict the mobility of individuals through the uni-, bi- and multilateral introduction of various lock-in, mobility and transaction taxes and address potentially harmful tax practices without a significant economic presence in other jurisdictions. In addition, these countries discuss alternative nexuses to safeguard and protect existing and to establish new taxing rights and support the idea of a Global Minimum Wealth Tax of 2% (GloWT) in order to reduce inequality and to curb international tax competition. The proposed GloWT addresses the potential failure in the progressive taxation of income and (unrealized) capital gains and is regarded as a comprehensive backstop and as an alternative to a presumptive income tax or an income tax with a broad notion of income.

The growing tension between tax sovereignty and equity as well as the various fiscal measures and nexuses to establish and allocate taxing rights on income and wealth of individuals to boost versus curb international tax competition have a significant influence on the future taxation of mobile Individuals including their family offices and wealth structures and bear the risk of both another race to the bottom and of growing fiscal restrictions for globally mobile individuals.