At a glance

• The UBS Billionaire Ambitions Report 2025 found that 36% of surveyed billionaire clients have relocated at least once, with a further 9% considering it.
• Henley & Partners recorded a 28% year-on-year rise in residence and citizenship applications in 2025, from clients across 100 nationalities and more than 60 programme options worldwide.
• Wealthy families increasingly hold two or three residencies at once: a primary base, a European residency for Schengen access, and often a non-European jurisdiction for tax or contingency.
• The driver is jurisdictional risk being treated like financial risk. Concentration in a single political and tax system is now seen as the same kind of exposure as concentration in a single asset class.
• Italy occupies a specific position in these structures: certainty of approval before capital is deployed, no minimum staying requirement, and underlying investments in established companies.

There is a conversation happening in family offices and adviser meetings across North America, the UK, and the Gulf that did not exist five years ago. A second residency strategy is no longer treated as an outlier decision, and the question has shifted from whether to secure one to how many, where, and in what order.

The headline numbers tell part of the story. The UBS Billionaire Ambitions Report 2025 found that 36% of surveyed billionaire clients had relocated at least once, with a further 9% considering it. Henley & Partners reported that 2025 application volumes for residence and citizenship programmes were 28% higher than the previous year, with applications received from 100 nationalities across more than 60 programme options worldwide.

But the more interesting shift is not the volume. It is the structure. Wealthy families are increasingly holding two, sometimes three, residencies at once. A base inside the European Union. A second outside it. Occasionally a third for specific use cases, education, business, or contingency. The pattern is recognisable to anyone who has spent time around portfolio construction. Geographic concentration risk is now being treated the same way as asset concentration risk.

What is driving the rise in second residency planning?

The first force is the speed at which policy now moves. The abolition of the UK non-domicile regime in April 2025, after more than two centuries on the books, was the clearest signal yet that long-standing tax frameworks can be dismantled within a single political cycle. Italy’s flat tax has been adjusted twice in three years. Greece’s golden visa property thresholds have moved. Portugal’s citizenship clock has been formally lengthened. Investors have absorbed the lesson: not that any particular rule is unstable, but that all of them are subject to change on timelines shorter than the wealth-planning horizon they were built into.

A second force, working alongside the first, is the broader sense that the institutional pillars of the post-war order are no longer fixed reference points. NATO, the EU, the multilateral trade system, the American security guarantee. Whether any of these will be different in ten years is a matter of opinion. But the question is now being asked seriously inside private banks and family offices.

Generational change is the third. Wealth holders in their fifties and sixties are increasingly thinking about the world their grandchildren will inherit, not the world they themselves built capital in. The planning horizon has lengthened just as the political horizon has shortened. Optionality is the rational response to that mismatch.

How does residency stacking actually work?

The investors building these structures are not preparing to flee. Most have no intention of leaving anywhere. What they are buying is the right to leave, the right to stay, and the right to choose without urgency when the time comes.

A typical multi-jurisdictional structure

A typical configuration looks like this. First, a primary residency where business, family, and most assets remain. Second, a European residency, often Italian, Portuguese, or Greek, providing access to the Schengen area, healthcare and education infrastructure for family members, and a credible base inside a politically diversified bloc. Third, a non-European residency, often in Latin America, the Gulf, or selectively in Africa, providing exposure to a different regulatory and tax universe and a hedge against the assumption that Europe and North America will continue to behave like the same place.

The Gulf as a counterweight to Europe

The Gulf has emerged as a natural counterweight to a European base. The UAE in particular has built a residency framework around zero personal income tax and long-term renewable visas. For some families, that pairing alone, a European residency for cultural and Schengen access, a UAE residency for tax flexibility, is now the default rather than the sophisticated choice.

Latin America as a contingency layer

Meanwhile, Latin American programmes serve a different function. Panama, Paraguay, and a handful of other jurisdictions offer relatively quick residency at modest thresholds, often without the staying requirements that more developed programmes impose. For families who want a contingency option that does not require relocating any meaningful part of their lives, these can sit in the portfolio at low cost.

In short, what unites the stacking strategies is the disqualification of single-jurisdiction thinking. The investor who builds a complete answer in Italy alone is making the same kind of decision as one who holds all of their capital in a single sovereign bond. It can be a very good decision. But it is rarely the most considered one.

Where does Italy fit in a second residency strategy?

Italy is rarely the only piece, but it is increasingly the centrepiece of the European piece.

The Italian Investor Visa approves the applicant before any capital is deployed. The family has certainty about the residency outcome before committing funds. This matters more when an investor is constructing a portfolio of jurisdictions rather than betting everything on one. They can move in sequence, with each piece confirmed before the next is built.

No minimum staying requirement

Beyond procedural certainty, the visa carries no minimum staying requirement. For an investor building a stack, this is essential. They are not relocating their life to Italy. They are placing one piece of a larger structure there, and they need that piece to function without demanding their physical presence for most of the year.

Why Italy works inside a second residency strategy

Equally important is the economic substance underneath the visa. Italy’s investment landscape includes household-name industrials, consumer brands, and financial institutions that have endured through several cycles and several political configurations. For an investor whose underlying concern is durability rather than upside, this matters. A residency programme that requires capital to sit in companies most of the world recognises is structurally different from one that requires it to sit in a single piece of property in a market they do not understand.

How the flat tax fits separately

There is also the flat tax regime, currently set at €300,000 per year for new applicants under the 2026 Budget Law. It is part of the calculation for some families and irrelevant to others. Worth noting is that the regime exists independently of the visa, which means the residency decision and the tax decision are made on their own merits. Families do not need both to be optimal for the structure to make sense.

Consider how this plays out in practice. A couple in their early sixties, based in Toronto, with grown children and an established business sold a few years ago. They have no intention of leaving Canada. What they want is to widen the field. They commit €500,000 to the Italian Investor Visa under the equity route, holding a portfolio of established Italian companies. The Nulla Osta arrives within three months, the residency permit is issued shortly after the investment is made, and the family now has a European base with full Schengen access, no minimum staying requirement, and capital sitting in companies most of the world recognises. A year later they pair it with a UAE Golden Visa through a property purchase in Dubai, taking advantage of the zero-personal-income-tax framework for the income they earn from international consulting work. Neither residency requires them to relocate. The Canadian primary base remains intact. What has changed is the structure underneath it: a European piece and a Gulf piece, each doing different work, neither demanding more than periodic presence.

What should investors actually be asking?

The investor sitting in Toronto, London, Dubai, or anywhere else who is being told by their adviser to “look at a second residency” is having a conversation that has moved on.

The serious question is no longer whether to hold a second residency. It is what role each piece of the structure plays. Which jurisdiction provides Schengen access. Which provides tax flexibility. Which provides contingency. Which provides a base for the next generation. Which provides nothing but the right to walk away from any of the others.

This is portfolio thinking applied to geography. A second residency strategy done well is not about chasing programmes. It is about building a structure with each component selected for what it actually does, not for what it promises to be.

The mistake worth avoiding is treating any single residency as the answer. None of them are. A second residency strategy is a longer answer, built from pieces, and the question it is answering is one that, ten years ago, most families did not think to ask.

For investors building the European piece of that structure, Italy continues to offer something specific: certainty before capital, no obligation to relocate a life, and underlying investments in companies whose names survive political cycles. At Ariete, that is the work. The residency is the result. The investment, and the discipline behind it, is the reason it holds.

Get in touch to find out more.

Frequently asked questions

Is a second residency the same as a second citizenship?

No. A residency gives the right to live, and often work, in a country under defined conditions. Citizenship is a permanent legal status that includes a passport. Most investor visa programmes grant residency first, with citizenship available only after a long qualifying period of physical presence, language tests, and integration requirements. For most HNW families, the residency itself, not the eventual passport, is the practical objective.

How many residencies do most HNW families hold?

Two is now common. Three is increasingly seen at the upper end. A typical structure is a primary residency where business and family are based, a European residency providing Schengen access and a credible base inside the EU, and sometimes a non-European residency in the Gulf or Latin America for tax flexibility or contingency. The right number depends on the family’s actual exposure, not on what other families are doing.

Which European residency programmes are most relevant for stacking?

Italy, Portugal, and Greece are the three most commonly used. Each serves a different function. Italy offers approval before capital deployment, no staying requirement, and exposure to established Italian companies through the Investor Visa. Portugal historically offered a citizenship route, though the timeline has now been formally lengthened. Greece offers a real estate route at €400,000 in most regions and €800,000 in prime zones, with a narrower €250,000 option restricted to commercial-to-residential conversions and listed heritage buildings, though Golden Visa holders cannot be employed in Greece.

Does holding multiple residencies affect tax residency?

It can, but not automatically. Tax residency is determined separately from immigration residency, generally by where a person spends time, where their economic interests lie, and the specific rules of each jurisdiction. Holding a residency permit does not in itself make a person tax-resident there. Families building multi-jurisdictional structures should treat tax residency as a separate planning question requiring specialist advice in each relevant country.