The Bidding War Is Now Running in Reverse

Relocation used to be arbitrage. A family compared a high-tax jurisdiction with a low-tax one, priced the difference, and moved. The analysis was static because the two prices were.

Neither is static now, and they are moving in opposite directions. Entry prices are being raised, on schedules published in advance. Exit charges are being introduced behind departing residents, on schedules that are not. A family that models the destination and not the departure has priced one side of a two-sided transaction.

The entry side is being repriced upward, openly

Italy is the clearest case because the mechanism is a single number. The regime for new residents at article 24-bis of the income tax code was introduced in 2017 at 100,000 euro a year covering foreign-source income, for up to fifteen years, available to those not resident in Italy for at least nine of the preceding ten years. The 2026 budget law, Law No. 199 of 30 December 2025, raised that annual sum to 300,000 euro, with the amount for each qualifying family member rising from 25,000 to 50,000 euro.

Two details matter more than the headline. The first is that this is the second increase, not the first — the figure moved to 200,000 euro in 2024 before moving again — which establishes a direction rather than an event. The second is that it is not retroactive: the new amounts apply to those whose Italian residency begins on or after 1 January 2026, while earlier arrivals continue at the figure in force when they arrived. The regime prices by cohort, and the cost of a year of deliberation is now a permanent difference in annual liability rather than a delay.

There is a drafting point with a date on it. Article 24-bis is repealed with effect from 1 January 2027 and the regime restated at article 246 of the consolidated act on income taxes, Legislative Decree No. 117 of 19 June 2026, in the same terms and at the same figures. Nothing substantive changes. But from next January a document citing article 24-bis by number rather than by substance is citing a repealed provision, and family instruments drafted around this regime over the last nine years do exactly that.

Elsewhere the movement has been to close routes rather than reprice them. Spain repealed the investor residence provisions — articles 63 to 67 of Law 14/2013 — by Organic Law 1/2025 of 2 January, with effect from 3 April 2025; applications filed before that date continue under the rules that applied when they were made. Greece restructured rather than closed, with article 64 of Law 5100/2024 replacing a flat threshold with tiers: 800,000 euro across Attica, the regional unit of Thessaloniki, Mykonos, Thira and islands above 3,100 inhabitants; 400,000 euro elsewhere; and 250,000 euro surviving only for commercial-to-residential conversions and listed-building restorations, with a 120 square metre minimum, a single-property restriction and a prohibition on short-term letting.

That last point is worth stating precisely, because it is widely reported loosely. The 250,000 euro figure is not a cheap zone. It is a narrow category with construction conditions attached, and it is not available for an ordinary purchase anywhere.

The most consequential closure was not legislative at first instance. On 29 April 2025 the Grand Chamber of the Court of Justice held, in Commission v Malta, that a scheme granting nationality in exchange for predetermined payments or investments, absent any genuine connection between applicant and state, was contrary to Article 20 TFEU and Article 4(3) TEU — Union citizenship, the Court held, cannot result from a commercial transaction. Malta then legislated, by Act XXI of 2025, gazetted 24 July 2025. The sequence is the point: the route did not close because a government changed its mind about revenue.

The exit side is newer and less visible

Norway is the developed example. Exit tax is charged on unrealised gains on shares and securities, calculated as if realised the day before emigration, at an effective 37.84 per cent — 22 per cent applied to a base uplifted by a factor of 1.72 — above a basic allowance of 3,000,000 kroner, with share savings accounts and endowment insurance brought into scope. The material change, effective 20 March 2024, was to the deferral. Previously a departing resident could defer and, having held the assets for five years without selling, see the obligation lapse. That five-year expiry was removed and replaced with settlement within twelve years of departure regardless of whether a sale occurs, with instalments available, 70 per cent of dividends received during the period applied against the outstanding liability, and the charge triggered on death abroad. Becoming Norwegian-resident again within twelve years cancels it.

Read that as a design and the intent is legible. The previous rule made departure a timing exercise. The amendment converts it into a cost.

The Dutch position requires more care than it is usually given, and this is where commentary is currently unreliable. A bill introducing a 36 per cent annual charge on Box 3 assets, applying to unrealised increases in value as well as to income received, passed the House of Representatives on 12 February 2026. It is not law. It requires the Senate, its intended commencement is 1 January 2028, the Council of State advised against it, a parliamentary majority has separately asked for an alternative based on realised gains only, and on 25 February 2026 the Finance Minister announced that amendments to reduce or remove the unrealised-gains component were being prepared.

The accurate statement is therefore that one chamber has approved a measure whose central feature the responsible minister has already signalled will be changed. Anyone planning against it as settled law is planning against a proposal. Note separately that the Netherlands already operates a distinct and long-standing charge on emigration with a substantial interest — a protective assessment on unrealised gains in qualifying shareholdings, deferrable without interest on departure within the European Economic Area — and that is the provision which actually bites today.

What the two sides do together

Set the entry and exit sides beside each other and the planning problem changes shape.

Entry prices are published, dated and generally prospective, which makes them a timing variable a family can act on. Exit charges are legislated behind people who have already left or are leaving, and their design increasingly removes the waiting strategies that made departure a matter of patience. The asymmetry is structural rather than accidental: a state repricing entry is competing for arrivals and must advertise, while a state pricing exit is addressing people whose decision is already made and has no reason to.

Which means the sequence most families run — decide to move, choose the destination, then take advice on the departure — inverts the order in which the numbers become fixed.

There is a second-order effect worth naming, because it changes what advice is for. When both sides move, the value of an answer decays. A jurisdictional comparison prepared eighteen months ago described a set of prices that no longer exist in three of the five territories discussed above, and nothing about the document announces that it has expired. The useful output in a repricing environment is not a comparison but a monitoring position: knowing which instruments are in draft, which have passed one chamber, which apply by cohort and which by date. That is unglamorous work and it is the only kind that survives contact with a legislature.

Nothing here is legal or tax advice and no figure should be relied on without checking its current state, which in several of these jurisdictions has changed within the last year. Structures and relocations are designed alongside independent counsel in each relevant territory, and a principal considering one should take advice from an adviser unrelated to this firm. The single durable observation is narrower than any of the numbers: the entry price is quoted to you and the exit price is quoted about you, and only one of those is a negotiation you are present for.