COVID-19 changed many things. It changed the way people worked, the way companies operated, and the way families thought about education, healthcare and security. It also changed the way wealthy individuals think about where they live.

Before the pandemic, residence was often relatively static. A wealthy individual might have lived in London, Paris, Milan or Geneva for twenty years, with the location determined largely by business, family, history and established social networks. COVID disrupted that assumption. For the first time, many wealthy individuals discovered that they could operate significant parts of their personal and professional lives from somewhere else.

The question now is whether that change was temporary.

I do not believe it was.

COVID Changed the Psychology

The most important consequence of the pandemic was not necessarily the number of people who moved. It was the number of people who realised that they could move.

Technology made international business increasingly portable. Private wealth was already becoming more internationally diversified. Remote working became normal for large parts of the economy, while families became more conscious of healthcare systems, political stability and the resilience of institutions. Above all, wealthy individuals became much more interested in optionality.

That is a significant psychological change. A second residence was no longer simply a lifestyle purchase. Increasingly, it could be viewed as an insurance policy: an additional jurisdiction, an alternative base and a form of diversification against risks that might previously have seemed remote.

This was not entirely a new phenomenon. As I discussed earlier in The End of Easy Tax Planning in Europe, international wealth had already become increasingly mobile and cross-border structures increasingly important. COVID did not create that trend. It accelerated it and, perhaps more importantly, made it much more visible.

The Wealthy Have Always Been Mobile

The wealthy have always moved. Historically, affluent families have maintained homes in several jurisdictions, established companies offshore, used international financial centres, educated children abroad and diversified their assets geographically.

But COVID accelerated something different: it normalised the idea that the physical location of an individual does not necessarily have to correspond to the location of the business, the investment portfolio or even the family’s wider economic interests.

That distinction is extremely important.

The modern wealthy individual can operate across several jurisdictions without necessarily being permanently rooted in any one of them. The result is not necessarily that people become less connected to their home countries. Rather, they become more capable of maintaining meaningful connections with several countries simultaneously.

The Old Wealth Map Is Changing

For decades, the European wealth map was relatively predictable. London, Paris, Geneva, Zurich and Monaco occupied established positions as centres of wealth, finance and international business. Those centres remain important, but the geography of wealth is becoming considerably more complicated.

Dubai has emerged as a major global wealth centre. Singapore has become increasingly important in Asia. Portugal attracted internationally mobile families, while Greece became a major investment migration destination. Italy developed a particularly attractive regime for certain wealthy new residents, while Cyprus and Malta continued to compete for internationally mobile capital and businesses.

The UAE has become especially significant because it combines taxation, infrastructure, connectivity and a business-friendly environment with an increasingly sophisticated financial and professional-services ecosystem.

The competition is therefore no longer simply between a handful of traditional European financial centres. It is global.

Data available in 2023 already illustrated this shift. The Henley Private Wealth Migration Report 2023projected substantial net inflows of HNWIs into the UAE, Singapore, Switzerland, Greece and Portugal, among others. The significance is not merely the ranking of individual countries. It is the increasingly global nature of the competition for internationally mobile wealth.

Residence Is Becoming an Asset

Perhaps the biggest change is that residence itself is increasingly being treated as part of a wealthy family’s overall asset allocation.

A residence permit can provide mobility, access to education, family security, business access, lifestyle diversification, tax-planning opportunities and, perhaps most importantly, a contingency option. The value is therefore not necessarily contained in the document itself. The value is in the optionality that the document creates.

This helps explain why investment migration has continued to attract interest even as individual programmes have come under increasing political scrutiny.

As I argued in The Death of the European Property Golden Visa, the traditional property-based model was already coming under pressure well before the pandemic. COVID added another dimension: wealthy individuals began to think about geographic diversification in much the same way they think about financial diversification.

But Tax Still Matters

The pandemic did not eliminate tax competition. If anything, it made it more visible.

A wealthy individual who can work from several jurisdictions naturally begins asking a series of interconnected questions: Where should I be tax resident? Where should my company be based? Where should investment income arise? Where should my family live? Where should my assets be held?

These are no longer necessarily separate questions. They are becoming components of one strategic decision.

That does not mean wealthy individuals simply move to whichever jurisdiction has the lowest tax rate. That is an increasingly outdated way of looking at wealth migration. A jurisdiction needs much more than a favourable tax regime. The investor is also considering political stability, rule of law, banking, healthcare, schools, air connections, property, security, professional services, investment opportunities and quality of life.

Increasingly, the question is also whether the individual can establish a genuine economic presence.

This is one reason the modern wealth-migration decision is becoming considerably more sophisticated than a simple comparison of tax rates.

The Tax Regime Is Only One Part of the Equation

A low tax rate without the surrounding ecosystem is not necessarily attractive.

For a wealthy family, the quality of institutions can be as important as the headline tax burden. A jurisdiction may offer an attractive regime but still be unsuitable if banking is difficult, professional services are weak, schools are inadequate, international connectivity is poor or the legal environment lacks predictability.

The most competitive jurisdictions are therefore increasingly offering a broader proposition: taxation combined with infrastructure, legal certainty, financial services, connectivity, lifestyle and access to investment opportunities.

That is a very different proposition from simply selling a low tax rate.

The New Investor Is More Sophisticated

The investment migration industry has also matured.

The early Golden Visa market was often based on a relatively simple proposition: purchase a qualifying apartment, obtain residence and hold the property. That model was easy to understand and relatively easy to market.

The sophisticated investor is now asking much more difficult questions. What happens if the programme changes? What happens if the property market falls? What happens if the government changes the qualifying investment? What happens to my tax position? What is the exit strategy? What is my investment return? What happens to my family?

These questions reflect a fundamental change in perspective.

As I wrote in Why Investment Funds Are Replacing Real Estate in Migration Programmes, investment migration is increasingly moving away from the idea of simply purchasing an asset in order to obtain residence and toward the idea of allocating capital in a way that makes sense independently of the immigration benefit.

This is no longer simply an immigration decision.

It is becoming a wealth-management decision.

COVID Created the Optionality Mindset

This may ultimately prove to be one of the most permanent consequences of the pandemic.

Before COVID, a second residence was often viewed as a luxury. After COVID, it increasingly came to be viewed as diversification.

The same principle applies to investment. A wealthy family does not necessarily want all its assets in one country. Why should it want all of its residence exposure in one country? Why should its business exposure, tax exposure and family exposure all be concentrated in the same jurisdiction?

The pandemic made concentration risk much more visible.

For an internationally mobile family, diversification is no longer necessarily limited to financial assets. It can include jurisdictions, residences, banking relationships, schools, business operations and even tax systems.

Governments Are Responding

Governments have noticed the change, although they are responding in very different ways.

Some want to attract wealthy individuals and the capital, businesses and economic activity that can accompany them. Others are increasingly concerned about housing affordability, tax competition, money laundering, transparency and the broader public-policy consequences of investment migration.

Portugal had already moved decisively in this direction by December 2023. Law No. 56/2023, enacted in October 2023, ended new applications under several traditional real-estate-linked Golden Visa routes while preserving other qualifying investment routes. The legislation therefore did not eliminate investment migration altogether; it changed the type of capital Portugal was prepared to accept.

Ireland had taken an even more definitive step earlier in the year, announcing the closure of its Immigrant Investor Programme to new applications from 15 February 2023. The Irish government stated that the programme had attracted almost €1.252 billion since inception but concluded, after considering wider public-policy issues and international reviews, that it was appropriate to close it. See Irish Department of Justice: Closure of the Immigrant Investor Programme.

Greece, by contrast, chose to adjust rather than close its programme. From August 2023, the minimum property investment in selected areas was increased to €500,000, while the lower threshold remained in place elsewhere. Enterprise Greece reported that the programme had attracted more than €5 billion in investment over its first decade, with most of that investment directed toward real estate.

The result is an unusual situation: demand for international mobility is increasing at the same time that some governments are making traditional investment migration more difficult.

The Investor Is Looking for Stability

This is why programme stability may ultimately become more important than the headline investment threshold.

Suppose one country offers residence for €250,000 but has frequent political discussions about changing the programme. Another requires €500,000 but has a stable legal framework, a diversified investment route and a clear policy rationale. The second programme may ultimately be more attractive.

The wealthy investor is not necessarily trying to minimise the initial investment. He is trying to minimise uncertainty.

That is a different calculation.

For an investor deploying substantial capital, the cost of policy uncertainty can be much greater than the difference between two investment thresholds. A programme that looks inexpensive on paper may be expensive in practice if the rules are unstable or the qualifying investment lacks independent economic merit.

The Property Model Is Under Pressure

The decline of the traditional property Golden Visa is therefore part of a larger development. It is not simply about housing. It is about the changing relationship between immigration and investment.

A government can justify foreign capital more easily when it can demonstrate that the money is financing businesses, infrastructure, technology or other productive assets. It is more difficult to justify the same capital when it simply increases demand for an existing apartment.

This is why fund-based investment migration has become increasingly interesting.

Portugal’s decision in 2023 was particularly significant because the country did not simply close the door to investment migration. It redirected the programme away from direct real-estate investment and retained, among other routes, a qualifying fund route. The direction of travel was therefore clear: the question was becoming less about whether foreign capital should be admitted and more about where that capital should go.

Investment Migration Is Moving Into Wealth Management

The next generation of investment migration will increasingly sit somewhere between immigration law and wealth management.

The investor will not simply need an immigration lawyer. Depending on the size and complexity of the family, the structure may also involve a fund manager, tax adviser, private banker, lawyer, accountant, investment adviser and estate planner.

The residence decision becomes part of a much larger structure.

This is particularly true for families with significant international assets. Once residence is considered alongside taxation, liquidity, investment return, succession, banking and family governance, it becomes difficult to treat immigration as an isolated decision.

The Family Office Effect

Family offices are likely to accelerate this trend because a family office does not normally make decisions based on a single benefit. It looks at the total balance sheet.

Residence, tax, liquidity, investment return, succession, risk, governance, education and asset protection are all interconnected.

When investment migration is viewed through that lens, the traditional property Golden Visa starts to look relatively unsophisticated. A family office is more likely to ask whether the qualifying investment belongs in the family’s portfolio in the first place.

That changes the entire proposition.

The question is no longer simply whether an investment qualifies for residence. It is whether the investment deserves to be owned.

The New Geography Is About More Than Moving

There is another important point. We should not measure wealth migration simply by counting people who permanently relocate.

The modern wealthy individual may not live in one place throughout the year. He may spend part of the year in Monaco, part in London, part in Dubai, part in Switzerland and part somewhere else.

The relevant question is increasingly: Where is the centre of economic and personal life?

That is a much more complicated question than simply asking where somebody owns a house.

It is also a question that tax authorities increasingly care about. Residence cannot simply be declared because an individual holds a residence permit or owns a property. Tax residence generally depends on the applicable legal rules and the facts and circumstances of the individual.

This distinction is critical.

Having a residence permit, owning a property, spending time in a country and becoming tax resident there are four different things.

For example, Cyprus had already established both a 183-day and a 60-day test for tax residence, subject to the applicable conditions.

The broader lesson is that wealthy individuals need to distinguish immigration status from tax residence and both from the underlying reality of where their personal and economic lives are actually conducted.

Tax Authorities Are Paying Attention

Increased mobility also creates challenges for governments.

The European Commission had already identified investor residence schemes as raising concerns relating to security, money laundering, tax evasion and corruption. Its 2019 report noted that investor residence schemes existed in twenty EU Member States at the time and called for greater transparency and effective, independent oversight.

This matters because the more internationally mobile wealthy individuals become, the more important it becomes for governments to distinguish genuine relocation from purely documentary arrangements.

The sophisticated investor should therefore assume that residence, tax, banking, corporate activity and investment structures may increasingly be examined as parts of the same overall picture.

The Post-COVID Investor Is Not Going Back

I do not believe the post-COVID wealth-migration phenomenon is simply a temporary reaction to lockdowns.

The pandemic accelerated structural trends that were already developing: digital business, international investment, remote management, global families, multiple residences, international education and geographic diversification.

The technology and infrastructure supporting these trends are now permanent.

The behaviour has changed with them.

The pandemic effectively demonstrated that physical location is no longer as constraining as it once was. For people with sufficient resources, international mobility became not merely possible but manageable.

That lesson is unlikely to be forgotten.

But Not Everyone Will Move

There is an important counterargument. Most wealthy individuals will not simply abandon their home country.

Family ties matter. Business matters. Culture matters. Social networks matter. Reputation matters. For many families, the benefits of remaining connected to an established home jurisdiction will outweigh the advantages of a complete relocation.

The change is that they increasingly want an alternative.

That distinction is critical.

The future of wealth migration may therefore involve fewer dramatic permanent departures and more sophisticated diversification. The wealthy individual does not necessarily need to leave one country permanently. He may simply want the ability to live somewhere else if circumstances require it.

The Second Residence Becomes the First Option

A second residence can provide something that a tax adviser cannot.

It provides choice.

If the political environment changes, the family has somewhere else to go. If tax policy changes, the family has another jurisdiction to consider. If security deteriorates, there is another base. If business opportunities change, there is another market.

The option may never be exercised.

But having it has value.

This is why residence should increasingly be viewed as part of a family’s broader risk-management strategy rather than simply as an immigration product.

This Is Why Investment Migration Will Survive

The political backlash against Golden Visas should therefore not be confused with the end of wealth migration.

The demand is structural. Wealth is becoming increasingly international. Families are becoming increasingly global. Capital is increasingly mobile. Technology has reduced the importance of physical location for many businesses. Governments continue to compete for investment and talent.

The product is changing.

But the demand remains.

The question is what the product becomes.

As I argued in Citizenship by Investment: Product or Public Policy?, the future of investment migration is likely to depend increasingly on whether governments can demonstrate a genuine economic and policy rationale for the capital they seek to attract. The same principle applies to residence: the strongest programmes will increasingly be those that connect investor mobility with economic substance rather than simply selling access to a jurisdiction.

The Next Stage

The first era of investment migration was largely about property. The second became increasingly about residence. The next is likely to be about wealth architecture.

Where you live. Where you pay tax. Where you invest. Where you bank. Where your family is educated. Where your business operates. Where your assets are held.

These decisions are increasingly connected.

The wealthy investor does not necessarily need one perfect country. He needs a structure that gives him flexibility.

That is a much more sophisticated objective.

Permanent Change

COVID did not create wealth migration.

It accelerated it.

It showed wealthy individuals that geographic concentration carries risk. It demonstrated that businesses can operate across borders. It made international mobility more normal. And it encouraged investors to think about residence in much the same way they think about financial diversification.

The result is unlikely to disappear.

The European investment migration industry may be changing. Golden Visas may be changing. Property-based programmes may be disappearing. Governments may become more selective about the capital they want to attract.

But the underlying demand is not.

The wealthy will continue to seek better places to live, invest and protect their families. The difference is that they are becoming much more sophisticated about how they do it.

The future of wealth migration is therefore not necessarily about leaving one country for another.

It is about having the freedom to choose between them.