We are pleased to share that an article by Fernando Del Canto, “Why Private Wealth is the Next Tax Frontier”, has been published in Taxation magazine, the UK’s leading publication for tax professionals. The piece looks at how governments are gradually shifting their attention away from corporate taxation and towards the taxation of private wealth – a change that could reshape how individuals and families plan across borders.
From corporate focus to private wealth
For years, international tax debate has centred on multinational companies. The OECD’s Base Erosion and Profit Shifting (BEPS) agenda, together with global minimum corporate tax measures, have dominated reform. But as public pressure grows and government budgets remain stretched, attention is now moving towards private individuals, especially those with cross-border assets and complex structures.
This is not about deciding whether people move countries for tax purposes. That debate reflects an old model of planning, where the focus was on exploiting gaps and loopholes. What lies ahead will be very different. The new environment will demand genuine economic substance, greater transparency, and long-term sustainability.
Towards a possible “Pillar 3”
The OECD’s “Pillars 1 and 2” showed that global coordination on tax is possible, even if imperfect. Some experts are now speaking of a possible “Pillar 3” – aimed not at corporations but at wealthy individuals. While still at an early stage, the ideas being discussed include:
- Minimum global wealth taxes
- Harmonised inheritance rules
- Coordinated measures against the so-called “tax nomad”
Each of these proposals raises significant legal, political, and technical challenges. Yet the direction of travel is clear: private wealth will be more closely monitored and more consistently taxed across jurisdictions.
Implications for internationally mobile clients
For individuals and families with ties to the USA, UK, Ireland, and Spain – the core focus of our practice – these developments cannot be ignored. Structures designed solely for tax advantage may not stand the test of time. Instead, planning will need to reflect:
- Real substance and presence
- Anticipation of compliance changes
- A mindset of transparency from the outset
These are not just theoretical issues. They have practical consequences for succession planning, family governance, cross-border investments, and relocation strategies.
Looking ahead
Spain’s Beckham Rule and Digital Nomad Visa remain in place, but recent political and media debate shows how quickly regimes can come under pressure. Similar questions are being raised across Europe, while in the UK and elsewhere wealth taxes are once again on the political agenda.
At Del Canto Chambers, as the only dual Anglo-Spanish chambers, we continue to follow these trends closely. We aim to ensure that clients receive advice that is not only compliant today but resilient for tomorrow.
