Investment migration people in the news this week included:
- Paul Williams of La Vida
- Eric Major of Latitude Group
- Isobel Neilson of Fragomen
- Luigi Belluzzo of Belluzzo International Partners
- Marc Acheson of Utmost Group
- Raul-Angelo Papotti of Chiomenti
- Nicola Saccardo of Charles Russell Speechlys
- Charlie Sosna of Mishcon de Reya
- Francesco Guelfi of A&O Shearman
- Giovanni Raffa of Mistral Capital Ltd
- Marco Cerrato of Maisto e Associati
- Tomm Adams and Robert Salter of Blick Rothenberg
- Alexandra Britton-Davis of Saffery
- Rachel De Souza of RSM UK
- Qing Miao of Howard Kennedy
- Philip Munro of Withers
- Adam Jefferies of PKF Littlejohn
- James Quarmby
Spear’s – Argentina readies citizenship by investment as the EU leans on the Caribbean
Paul Williams, CEO of citizenship-by-investment (CBI) advisory firm La Vida, told Spear’s that the plans have already ‘generated some strong early interest’.
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‘It combines a competitive entry point with a passport which opens access to Europe, the UK, and several of the world’s top economies. That is exactly what our clients would be looking for in a Latin American option,’ he said.
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Eric Major is the CEO of Latitude Group, which is one of five investment migration firms advising Argentina’s government on the design and implementation of the scheme. Arton Capital, Passport Legacy, AIM Global and Apex Capital Partners are also involved.
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Major told Spear’s that work is underway on the ‘final trimmings of the programme’, and that President Javier Milei’s government is keen to get the scheme up and running before the end of the year, but legal challenges may thwart that timeline. As the programme was created by presidential decree, it is now before the country’s Supreme Court.
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‘It’s very exciting to see people in the industry talking about it, and hungry for information. There is a process of pre-registration that all these firms have started, and demand has been quite strong,’ Major said.
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Isobel Neilson, a director in the law firm Fragomen’s private client team, said that global mobility advisers have been ‘waiting for this with bated breath for a while’, but that HNWs should ask some questions of the scheme before going all in.
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‘How long is it going to last? Are the Argentinians going to shut it down next time there’s an election because they don’t like the way it looks to the rest of the world?’
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‘If you look at it broadly, citizenship by investment – particularly in Europe – is a thing of the past,’ she told Spear’s.
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‘The pivot that’s happened over the past few years is that things have become much more complicated. What we’re seeing our clients look at a lot more are these discretionary routes for citizenship, which are merit-based and based on exceptional contribution, and that’s a really different ball game.’
The Telegraph – Italy lured wealthy elites with low taxes. Now they’re in Meloni’s crosshairs
Luigi Belluzzo arrived at the Milan office of his advisory firm, Belluzzo International Partners, on Monday expecting it to be like any other day. But his phone began ringing and it didn’t stop.
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“How many clients called me that day? More than 50. Not only me, also all our partners,” he says.
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“Someone described it to me as ‘a honey trap’. You get enticed in with this flat tax but then if you decide to leave at some point in the future, you’re caught on the way out,” says Marc Acheson, a wealth adviser at London-based Utmost Group.
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That’s what Belluzzo’s clients are worried about. He says: “It was like a bomb, because the headline was ‘exit tax’ and so everybody thought, ‘Oh, it is hitting me?’”
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“The way it was framed was far from perfect. So it was like a cold shower for many people,” says Raul-Angelo Papotti, a Milan-based partner at law firm Chiomenti. “There are sound arguments to say that this does not apply to flat-tax participants. We would welcome clarification and we expect there will be.”
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Nicola Saccardo, a partner at law firm Charles Russell Speechlys, says Meloni has previously tried to maintain the new arrivals’ trust by avoiding retrospective changes to the regime.
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“Grandfathering has been rated very highly by clients. It is proof that if there is a change, it won’t affect those who moved before the change. That’s a source of great stability,” Saccardo says.
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Others are not so sure, including Charlie Sosna, head of private wealth and tax at law firm Mishcon de Reya. “Those who have moved to Italy went with an element of hesitation over the stability of the tax regime and whether it would change, particularly when they doubled the flat fee cost overnight,” he told The Telegraph earlier this week.
Bloomberg– Italy Exit Tax Plans Risk Upending Years Spent Courting Rich
“As it is currently drafted, it looks a lot like a convoluted form of wealth tax and gives the impression that the country is becoming a golden prison for the rich,” Francesco Guelfi, a partner at A&O Shearman in Milan, said in an interview.
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“This punitive proposal changes the rules of the game for people who decided to move to Italy years ago,” said Giovanni Raffa, head of capital raising at Mistral Capital Ltd who moved to Milan at the end of 2021 after 16 years in London.
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“I would have made the move anyway, because I was motivated by considerations beyond the tax incentives, but uncertainty over the rules is clearly a negative and could discourage others from making the same choice in the future,” he said.
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“What is unusual is not the exit tax itself,” said Marco Cerrato, a tax lawyer and partner at Maisto e Associati who helps clients relocate to Italy. Rather, it’s “the mixed signal Italy is sending after years of using generous tax incentives to attract wealthy people from abroad.”
Business & Accountancy Daily – Italy plans 26% exit tax after non dom drive
Tomm Adams, partner in global mobility and Italy growth hub lead at Blick Rothenberg, said news of the proposed exit tax had already unsettled some former UK non doms.
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‘I have spoken to several who are now considering leaving before 31 December. Some are calling it a bait and switch’, he said.
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Alexandra Britton-Davis, partner at Saffery, said despite planned changes, Italy’s flat-rate ‘remains attractive, particularly for taxpayers reassessing their options following the changes to the UK non dom regime’.
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‘Internationally mobile taxpayers want certainty when deciding where to base themselves, and repeated changes to the rules risk making Italy a less compelling proposition,’ Britton-Davis added.
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Similarly, Rachel De Souza, private client tax partner, RSM UK, said: ‘In reality, the introduction of an exit charge is unlikely to have a major impact on those looking to move to Italy.’
Spear’s – China’s wealthy pay £18bn under offshore trusts tax crackdown
Howard Kennedy partner Qing Miao told Spear’s that ‘most’ of her clients ‘are working with the trustees to unwind the trust or to distribute the trust’s assets’, and that other professionals have reported the same thing.
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‘There’s also speculation about the Chinese tax authorities that offshore trusts are just the first step, and they are going to look at offshore companies as well, in particular Cayman and the BVI,’ Miao told Spear’s.
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The PRC’s measures received much media attention when announced in July, but Withers’ partner Philip Munro told Spear’s there is a concern that some trustees may still be unaware of the changes (which include a daily surcharge for every day that taxes are not paid).
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‘I think where the danger is if you’re a trustee and you’ve only got a couple of matters, or a single matter of a Chinese connection, and this hasn’t been brought to your attention,’ he said. ‘Then you’re potentially in quite a difficult position, particularly now that the deadline has passed.’
Birmingham Mail – New HMRC 4-year tax break confirmed with wealthy people already exploiting it
Rachel de Souza, of tax firm RSM, said: ‘They are in the fortunate position that under the new rules they will get four years of tax relief on any foreign income and gains.
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‘But there is a smaller cohort who were ready to return, but, for example, have only been away for nine years, so now might stay out one more year.’
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Adam Jefferies, of tax firm PKF Littlejohn, said: ‘The new rules are stricter for non-doms, but for British citizens they’re much better.’
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Robert Salter, of tax firm Blick Rothenberg, said: ‘Previously, if you were British domiciled, born in the UK, you were going to find that it was very difficult to avoid the IHT trap. Whereas it’s definitely a lot more doable now.’
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James Quarmby, a tax lawyer, said: ‘If I’m British and I have been living in Spain for over ten years, I can come back to the UK, and be outside of inheritance tax on foreign assets for ten years after returning.
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“I think we’ll see people coming back to the UK if they don’t think they will live for that long. And there are far more expat Brits than non-doms.’
