Europe’s evolving wealth, capital-gains, and exit-tax debate is changing the calculations of internationally mobile investors. This analysis separates the policy signal from the headline noise.
Carlo Alberto Rovere IMCM, ICWIM
A few months ago the news broke that the Dutch Parliament had approved a reform introducing a 36% annual tax on unrealised gains - stocks, bonds, and crypto. Not when you sell, but every single year on paper profits.
Within days, 50,000 Dutch citizens signed a petition. Just two weeks later, the Finance Minister reversed course, admitting “something simply hasn’t gone right.” The most aggressive part is now being rewritten.
But even if the final tax ends up being less extreme, the fact that such a proposal was seriously advanced and nearly passed reveals a lot about the direction of European tax policy.
This isn’t just a Dutch issue. It’s a worrying pattern repeating across Europe.
The numbers nobody wants to hear
What follows isn't opinion. It's public data from national tax authorities and OECD reports that rarely make it into mainstream conversation:
France’s ISF wealth tax collected around €4-5B per year. Some studies suggested that capital flight and reduced economic activity may have offset a significant portion of that revenue. Norway increased its wealth tax rates and has seen notable outflows of high-net-worth individuals, raising questions about the net impact on total tax revenue. Spain targeted €1.5B with its solidarity tax, but initial collections were lower than expected due to regional offsets and tax planning. In many cases, the revenue generated by wealth taxes tends to fall short of initial projections.
Capital is mobile. Governments are not. And that gap is widening every year.
Country by country: who is taxing what
Netherlands (Watch closely)
49.5% top income tax · Box 3 regime: in transition
No formal wealth tax on real estate, but the Box 3 regime taxes liquid assets (stocks, bonds, crypto) based on assumed returns - currently being challenged and rewritten. In February 2026, parliament approved a new Box 3 reform that would impose a 36% annual tax on actual unrealised gains from January 2028. Within days, 50,000 citizens signed a petition against it. The Finance Minister reversed course weeks later, acknowledging the plan needs to be rewritten before Senate consideration.
⚠ The Box 3 situation remains unresolved. A new version is expected before Senate review. Anyone holding significant liquid assets in the Netherlands should be watching this closely - - the direction of travel is clear even if the final shape is not.
60.5% top income tax · Highest rates apply at high income levels
Denmark has one of the highest marginal income tax rates in the developed world. While top rates apply only at higher income levels, taxpayers enter relatively high tax brackets at comparatively modest salaries by UK or North American standards.
PM Frederiksen has proposed reinstating a wealth tax (abolished in 1997), targeting the top 1% and projected to raise around $1B per year. Denmark’s Tax Law Council has also discussed the possibility of introducing taxation on unrealised crypto gains, although this remains under review and has not been implemented.
United Kingdom ("exit tax" in progress)
45% top income tax · No formal wealth tax - but something worse
A cascade of policy shifts created what has been dubbed a "Wealth Exit": abolition of the 200-year-old Non-Dom regime (effective April 2025), worldwide taxation of all global income after a 4-year grace period, a 40% inheritance tax on worldwide assets for long-term residents - not just UK-located ones - and trust protections removed for offshore assets. A 20% exit tax on unrealised gains from UK business assets has been floated but is not yet law. The threat alone accelerated departures.
Norway (Wealth tax: active)
47.4% top income tax · Net wealth tax: 1.0-1.1%
Progressive net wealth tax on global assets above NOK 1.9M, including illiquid business assets - meaning entrepreneurs can face a bill on assets they cannot easily sell. A strict exit tax of 37.84% applies to unrealised gains for anyone moving abroad. Result: more millionaires per capita have left Norway than any other country. 80+ billionaires and multimillionaires departed between 2022 and 2025, mostly relocating to Switzerland.
Spain (Wealth tax: active)
51% top income tax · Wealth tax: 0.2-3.5% on worldwide assets
A national Solidarity Tax on Large Fortunes (on net wealth exceeding €3M) overrides regional exemptions - including Madrid's 100% wealth tax rebate. The result is significant internal migration from Catalonia to Madrid, causing "tax drainage" between regions.
Switzerland gains 300-500 ultra-wealthy residents annually from Spain, Norway, Germany, and the UK.
The structural problem no one can fix
By 2050, there will be 52 Europeans aged 65+ for every 100 workers - up from 33 today. Italy already spends 15.3% of GDP on pensions alone. Spain's debt is projected at 129% of GDP by 2050, driven almost entirely by ageing costs.
Governments aren't taxing to invest. They're taxing to stay afloat.
In 1990, twelve OECD countries had wealth taxes. Today, only three remain. Every country that raised rates saw capital and people leave.
The exit door is a two-hour drive to Switzerland or Gibraltar or a flight to Cyprus, Panama or Paraguay. Even Dubai, despite current uncertainties, remains a strong option for residency.
Why more people are quietly choosing Paraguay (South America)
I work across Latin America and I watch this trend up close. Paraguay isn't an exotic destination or a grey-area tax shelter. It's a country that has built a logical, stable, and genuinely attractive tax system - the exact opposite of what Europe is trying to construct.
Permanent and temporary residency can be obtained in months, with a modest standard documentation. Minimum physical presence required to mantain the fiscal residency.
For a Dutch entrepreneur staring at a potential 36% annual tax on shares they already own, or a British founder calculating a 40% succession tax on assets built over thirty years - Paraguay isn't a plan B. It's the rational response to tax policy that has become irrational.
This is not anti-European rhetoric. I have real respect for the social systems these countries have built over decades. But what I see on the ground today is different: people are actively restructuring their lives around the timing of laws that didn’t even exist three years ago. At this point, it’s no longer theoretical. It’s happening.
The window to act before broader EU-level coordination is implemented is still open. The European Commission is already working on a bloc-wide approach to wealth taxation, with developments expected before summer 2026. That window exists today - but it won’t stay open for long.
About the author
Alberto Rovere is the Managing Partner of Allie International Ltd. and co-founder of TaxNomadism™. With over 12 years of experience in global mobility, citizenship and residency by investment (CBI/RBI), and international structuring, he advises high-net-worth individuals, entrepreneurs, and family offices on building flexible, multi-jurisdictional solutions for wealth protection.
Disclaimer
This content is for informational purposes only and does not constitute tax, legal, or investment advice. Each situation is different and should be evaluated with qualified professionals in the relevant jurisdictions before taking any action.
