Jurisdiction Strategy

Where Should a Family Office Live?

The decision is real, the criteria are knowable, and the smartest answer is often not to choose a single country at all.

Ask where a family office should be based and you will get a list of countries. That is the first mistake. The question is framed as a single destination, and framed that way it quietly assumes the family should pin its structure, its people and its future to one flag. The families who get this right rarely do that. They treat location as a set of decisions to be made separately, and they keep the freedom to change their minds.

The backdrop is real movement, not theory. Henley & Partners projected a record 142,000 millionaires relocating in 2025, with the United Kingdom forecast to lose 16,500 of them, the largest outflow it has ever recorded, and the UAE gaining a record 9,800. Capital is voting with its feet. The interesting work is understanding what it is voting on.

What actually drives the decision

Strip away the brochures and the choice comes down to a stable set of criteria. They are knowable, and they can be weighted against a family's own priorities.

  • Tax exposure. Not headline income tax, but the full picture: income, capital gains, dividends, and above all inheritance and exit taxes, which do the real damage across a generation.
  • Rule of law and enforceability. Whether the courts are independent, whether contracts and structures hold, and whether a trust or foundation created there is recognised where it matters.
  • Political and monetary stability. The probability that the rules, the currency and the government still look familiar in twenty years.
  • Personal safety and quality of life. The part families underweight until they live somewhere, then never stop weighing.
  • Financial ecosystem and talent. Depth of private banks, advisers, lawyers and hireable investment professionals. The Global Financial Centres Index is the standard objective measure.
  • Banking acceptance and reputation. Whether a structure from that jurisdiction opens accounts and clears correspondent banking without friction, and how it reads to a regulator or counterparty.
  • Substance and operating cost. What it genuinely costs to run a compliant office there, and the real staff and premises required to hold the tax treatment.
  • Succession treatment. Forced heirship, inheritance tax, and whether the family's chosen governance survives a death intact.
  • Mobility and family access. Residence and visa pathways for the principals and the next generation.
  • Regime durability. The most underrated criterion by far: how likely the deal is to still exist when you need it.

That last point deserves its own weight, because the recent record is brutal on anyone who treated a tax regime as permanent. The United Kingdom abolished its 226-year-old non-domiciled regime on 6 April 2025, replacing it with a four-year window and, for many, full exposure to inheritance tax. Portugal closed its Non-Habitual Resident regime to new applicants. Italy's flat tax on foreign income, introduced at 100,000 euros in 2017, was doubled to 200,000 in 2024 and raised again to 300,000 for 2026. Several Swiss cantons, including Zurich and Basel, abolished lump-sum taxation by referendum years ago. The lesson is not that these places are bad choices. It is that any single choice is a depreciating asset.

The objective landscape

Measured against those criteria, a short list of hubs does most of the work in serious conversations. None of them wins on every axis, which is the point.

Hub Personal tax Legal system FO viable from Ecosystem (GFCI 37) Watch
Dubai (DIFC) No income or capital gains tax English common law, own courts ~USD 30-50m 12th, leading in region Office entity itself taxed at 9%; 0% needs substance
Abu Dhabi (ADGM) No income or capital gains tax English common law, applied directly ~USD 30-50m Regional top tier Smaller ecosystem than Dubai; strong on foundations
Singapore No capital gains tax Common law, highly rated S$20-50m in the fund 4th 13O/13U thresholds tightened in 2025; incentive sunsets 2029
Switzerland Lump-sum (forfait) available Civil law, very stable ~USD 150m Zurich, Geneva top 20 Not all cantons offer forfait; higher cost base
Hong Kong No capital gains tax Common law Comparable to Singapore 3rd Political and China-exposure risk to weigh
Italy (Milan) 300k flat tax on foreign income Civil law, EU Residence play, not FO hub Milan mid-tier Flat tax raised twice in two years

A few honest nuances the table cannot hold. The Gulf leads on tax, personal safety and cost, and the UAE has removed real friction: a single family office in the DIFC no longer needs to register as a designated non-financial business, and the centre now runs a dedicated Family Wealth Centre. But the family office company there is a taxable service entity at 9 percent, not a tax-free wrapper, and on the standard rule-of-law and political-rights indices the region scores lower than Switzerland or Singapore. That is a trade a family should make with open eyes, not by accident.

Switzerland and Singapore sit at the opposite corner: deep ecosystems, strong courts, decades of predictability, at a higher cost and, in Singapore's case, after a visible tightening of the family-office rules following its 2023 money-laundering scandal. Hong Kong offers a first-class common-law financial centre with a discount that reflects exactly the risk you are being paid to take. Europe's flat-tax jurisdictions are residence plays for the principals, not homes for the office itself.

The unbundled alternative

Here is the move most advisers will not lead with, because it sells fewer relocations: do not relocate the family office as a single unit at all. Unbundle it.

A family office is really three layers that happen to be discussed as one. There is the ownership layer, where the assets legally sit, which rewards a stable, boring, well-recognised structure jurisdiction such as a Liechtenstein or Jersey foundation or a Singapore trust. There is the management layer, where decisions are actually made and the team has substance, which rewards ecosystem and talent. And there is the residence layer, where the principals physically live, which rewards tax and lifestyle. Nothing requires these three to share a country. Forcing them to is how families end up over-optimising one axis and quietly failing the others.

Then treat jurisdiction the way you treat a portfolio: acquire optionality and hold it in reserve. A second residence right in a different bloc, obtained before you need it. A standby structure, drafted and dormant, that can be activated in weeks rather than quarters. The families who moved fastest and cheapest out of the UK in 2025 were not the ones who reacted in April. They were the ones who had arranged the option years earlier and simply exercised it. Optionality, again, is the asset. Relocation is just one way to spend it.

None of this is a loophole, and it is not free. Unbundling raises the two hardest questions in cross-border planning: substance, because a tax treatment you cannot defend with real people and real activity is a liability waiting to be assessed; and management and control, because the office is the entity most exposed to being dragged into the tax net of wherever its decisions are genuinely taken. Add controlled-foreign-company rules, common reporting standard transparency, and the plain cost of running more than one seat, and the unbundled model is only for families with enough scale and enough governance to carry it. But for those families, it answers the real question, which was never "which country," but "how do we never again be trapped by one."

The point

Jurisdiction is not a destination you arrive at. It is a set of exposures you manage. The winners over the next decade will not be the families who picked the best country in 2025, because 2025's best country is already being re-priced by its own parliament. They will be the ones who arranged, quietly and in advance, never to depend on the answer.

Sources

  1. Henley & Partners, Private Wealth Migration Report 2025 (millionaire inflow and outflow projections).
  2. Z/Yen and Long Finance, Global Financial Centres Index 37, March 2025 (financial-centre competitiveness).
  3. Monetary Authority of Singapore, fund tax incentive updates (Sections 13O and 13U), summarised by Withers and BDO.
  4. UAE Cabinet Decision No. 100 of 2023 on the Qualifying Free Zone Person regime; DIFC and ADGM family-office framework, discussed by Boru Consulting.
  5. HMRC / UK Government, abolition of the non-domiciled regime from 6 April 2025 and the Foreign Income and Gains regime, summarised by KPMG.
  6. Italian flat-tax trajectory and Swiss lump-sum taxation, summarised by IMI Daily.