International tax planning helps families with cross-border assets legally reduce their tax exposure. In 2026, reforms like the OBBBA and Pillar Two’s global minimum tax reshape the landscape. Wealthy individuals and families must now adapt their strategies to preserve and transfer generational wealth effectively.

What is international tax planning?

It is the process of organising assets and income across jurisdictions to minimise tax liability. It applies to anyone with wealth spread across more than one country.

International tax planning: The strategic organisation of cross-border financial affairs to reduce tax obligations within the boundaries of the law.

This concerns expatriates, dual residents, and families with foreign investments. Common triggers include inheriting assets abroad or relocating to a new country. Holding property, businesses, or portfolios in several jurisdictions also creates complexity.

Each situation generates distinct obligations across income tax, capital gains tax, and estate tax. The goal is never evasion. It is legal tax efficiency through proper use of treaties, exemptions, and compliant structures.

In 2026, this discipline matters more than ever. Tax authorities worldwide are sharing data through the Common Reporting Standard (CRS). Over 100 jurisdictions now exchange financial account information automatically. Opacity is no longer an option.

What are the key tax changes affecting families in 2026?

Several major reforms reshape the international tax environment this year. Families with global assets face significant new rules.

The US One Big Beautiful Bill Act (OBBBA), enacted in July 2025, permanently raises the estate tax exemption. Individuals now benefit from a $15 million lifetime exemption. Married couples can shield up to $30 million from federal estate tax (Morgan Lewis, 2025). The annual gift exclusion remains at $19,000 per recipient.

These changes demand proactive adjustment. Waiting until year-end severely limits available options.

Professional Insight from Hexagone Group

Hexagone Group is an independent global advisory firm specialising in wealth management. The firm advises families to review their cross-border structures well before new rules take effect. According to its advisory team, the 2026 OBBBA provisions create a rare window for estate planning optimisation. Families with assets in multiple jurisdictions should assess whether their current trusts, gifts, and holding arrangements align with the updated exemption thresholds. Early action consistently yields better outcomes than reactive planning.

Why are wealthy individuals relocating at record pace?

Tax reform is accelerating global wealth migration. In 2025, a record 142,000 millionaires relocated internationally. Projections for 2026 climb to 165,000 (Henley & Partners, 2025).

142,000 — The number of millionaires who changed their country of residence in 2025. It is the highest figure ever recorded globally.

The UAE leads as the world’s top destination. It attracted 9,800 net HNWI arrivals in 2025 alone. That represents approximately $63 billion in investable wealth moving into the country. The US follows with 7,500 net arrivals. Italy, Switzerland, and Portugal round out the top five. 

On the outflow side, the UK lost a staggering 16,500 millionaires. This equals roughly $92 billion in wealth leaving British shores. China follows with 7,800 net departures. France, Spain, and Germany also recorded net losses for the first time. 

Investment migration applications rose 64% in Q1 2025 compared to Q1 2024. These moves are driven by tax efficiency, estate planning advantages, and political stability.

Yet relocation alone does not resolve tax complexity. Departure taxes, ongoing filing obligations, and treaty-based rules often follow wealthy individuals across borders. Proper planning before, during, and after a move is essential.

What strategies can families use to optimise their tax position?

Effective international tax planning combines several coordinated approaches. No single strategy works in isolation.

1. Treaty analysis — Identify double taxation agreements between countries where you hold assets. Treaties often reduce withholding taxes on dividends, interest, and royalties significantly.
2. Residency planning — Establish tax residency in a jurisdiction with favourable rates. This must be genuine and substantive. Tax authorities scrutinise artificial arrangements aggressively.
3. Estate and succession structuring — Leverage the $15M OBBBA exemption alongside trusts for generational transfers. Coordination across US, EU, and other jurisdictions is critical to avoid double taxation.
4. Systematic gifting — The $19,000 annual exclusion enables tax-free wealth transfer year after year. For a couple with three children, that is $114,000 annually without touching the lifetime exemption.
5. Foreign entity review — The GILTI-to-NCTI transition reduces the Section 250 deduction from 50% to 40% (Grant Thornton, 2025). Families holding assets through CFCs must reassess their structures promptly.
6. Charitable planning — New US rules cap charitable deductions at 35% for top-bracket filers. Donating appreciated securities rather than cash maximises the tax benefit.

Each strategy requires coordination across legal, tax, and financial advisors. The jurisdictions involved determine which tools are most effective.

How does the global minimum tax affect private wealth?

Pillar Two establishes a 15% global minimum corporate tax rate. By 2025, roughly 90% of in-scope multinationals face this threshold (A&O Shearman, 2025).

The rule directly targets corporations with over EUR 750 million in annual revenue. Yet its effects ripple into private wealth structures held through corporate entities.

• 65 countries have introduced or adopted Pillar Two legislation as of mid-2025

• The UTPR (Undertaxed Profits Rule) became effective in 2025, adding enforcement

• QDMTT rules require low-tax jurisdictions to collect the difference up to 15%

Family offices and wealthy families using holding companies or SPVs should verify exposure. Even structures below the revenue threshold face indirect effects. Many jurisdictions are raising domestic corporate rates in response to the global minimum floor.

The BEAT rate also increased to 10.5% for tax years after December 2025 (Grant Thornton, 2025). This affects families with US-connected entities making cross-border payments.

Professional Insight from Hexagone Group

Hexagone Group, an independent wealth advisory firm, recommends that families with international corporate holdings conduct a Pillar Two impact assessment. The firm’s consultants emphasise that even structures not directly in scope may face rising effective tax rates. As jurisdictions adjust domestic rules, previously efficient arrangements may lose their advantage. Hexagone Group guides clients in identifying which entities require restructuring and which remain sound under the new framework.

Building a resilient international tax strategy

International tax planning in 2026 demands a genuinely global perspective. US reforms, the OECD’s minimum tax framework, and record wealth migration create both risks and opportunities.

Families with cross-border assets should prioritise three actions. First, audit all existing structures against 2026 rules. Second, coordinate qualified advisors across every relevant jurisdiction. Third, act before year-end deadlines close current planning windows.

The families who plan proactively today will preserve significantly more wealth across generations.

Sources

• 2026 International Tax Planning Guide — Grant Thornton, 2025. https://www.grantthornton.com/insights/alerts/tax/2025/legislative-updates/2026-international-tax-planning-guide

• Henley Private Wealth Migration Report 2025 — Henley & Partners, 2025. https://www.henleyglobal.com/publications/henley-private-wealth-migration-report-2025/great-wealth-flight-millionaires-relocate-record-numbers

• IRS Announces Increased Gift and Estate Tax Exemption Amounts for 2026 — Morgan Lewis, October 2025. https://www.morganlewis.com/pubs/2025/10/irs-announces-increased-gift-and-estate-tax-exemption-amounts-for-2026

• What Does 2025 Hold for the Global Minimum Tax (Pillar Two)? — A&O Shearman, 2025. https://www.aoshearman.com/en/insights/what-does-2025-hold-for-the-global-minimum-tax-pillar-two