The DATA ROOM column of the Corriere della Sera of December 9, 2021, conducted a survey on the international mobility of the rich, that is, those people who own net worth in liquid assets of at least one million dollars. These are 18.7 million “High-Net-Worth Individuals” with assets from 1 to 5 million dollars; 1.89 million people are “Mid-tier Millionaires” with assets from 5 to 30 million dollars; 200,900 people “Ultra High-Net-Worth Individuals” with assets over 30 million dollars. The world ranking by country sees the United States in the first place, followed by Japan, China and France. Although the reasons that lead the rich to emigrate by attraction are many (including the reputation of the country of destination, health care, the level of schools and universities, public safety) the main one is the tax regime, more costly in the country of origin, more favourable in the chosen country.

In analyzing the tax treatments adopted by the EU Member States to attract the rich, the ranking compiled by the EU Tax Observatory, an independent research institute dealing with tax evasion and avoidance, is of particular interest.

The Observatory’s study recently published in November shows that the number of Member States that have adopted special preferential schemes for millionaires and wealthy people (non-EU, EU and their “returning” citizens) has increased from 5 in 1995 to 28 in 2021, meaning that all Member States adopt policies of attracting foreign capital to increase revenues and encourage investment. The Observatory calculates that in 2021 there are about 200 thousand people who have benefited from these policies. This number includes, in addition to millionaires, also pensioners, and highly qualified workers with high incomes.

When only considering millionaires, Italy is the most attractive country as the tax regulations adopted with the 2017 Budget Law provides for flat-rate taxation of 100 thousand euros per year on income produced abroad whatever the amount. The benefit lasts for 15 years and extends to family members who have even more advantages as they pay the Italian State 25 thousand euros a year. The numbers of rich people who have transferred their tax residence to Italy are eloquent: 98 in 2017; 263 in 2018; 429 in 2019; 790 in 2020, with a revenue for the State, in the last year, equal to 64.1 million euros.

There is no lack of criticism of this extremely favourable regime, especially since the benefit is detached from the investments that instead should have been a condition for obtaining them.


Featured image: via Freepik.