🇪🇸The Wealth Tax Map: Country by Country

Concept

Income tax sees only the flow. A wealth tax takes an annual bite out of the stock itself — property, portfolios, shareholdings, yachts — net of debt. The political logic runs on two tracks: levelling, because capital grows faster than wages, and fiscal insurance for the years when income hides inside the retained earnings of a personal holding company.

Practice turned out to cost more than theory. In the 1990s roughly a dozen OECD countries ran an annual net wealth tax; by the end of the 2010s only a handful were left. Valuing illiquid assets every year is expensive, the base leaves with its owners, and receipts rarely clear a fraction of a per cent of the budget. Sweden, Austria, Germany — where collection has been frozen since 1997 — and ISF-era France dropped out one after another.

Three models held. Switzerland, where the cantonal tax is a century-old part of the bargain: restrained taxation of income plus a wealth tax of its own. Norway, with formuesskatt as an article of faith. And Spain, which brought the tax back "temporarily" in 2011 and has never let go of it. In the 2020s the subject returned to the global agenda — post-pandemic deficits, the inequality debate, Zucman's proposal to the G20 for a 2% minimum on billionaires. For practitioners something else matters more: the map is made of individual jurisdictions, and it is the map that decides where a client can actually move.

The 2026 Map

Spain

Impuesto sobre el Patrimonio is a regional tax: the default scale runs 0.2–3.5%, and the autonomous communities are free to change the rates and grant a bonificación. Madrid and Andalusia zero it out with a 100% bonificación. Layered on top since 2023 is the federal backstop, ITSGF, on net wealth above €3M (after the general €700k allowance and up to €300k for a main home):

• €3–5.35M — 1.7%;
• €5.35–10.7M — 2.1%;
• above €10.7M — 3.5%.

The regional tax is credited against ITSGF, so in regions running the full scale the backstop is barely visible. Madrid (Ley 12/2023) and Andalusia (DL 7/2023) answered in kind: for as long as ITSGF is in force they trim the bonificación by the amount of the backstop and collect it themselves as regional Impuesto sobre el Patrimonio. The "temporary" ITSGF has been extended "until regional taxation is reviewed" — indefinitely, in practice. The detail is worked through in the Spanish profile.

Norway

Formuesskatt for 2026, per the Prop. 1 LS (2025–2026) budget:

• a threshold of NOK 1.9M per person, doubled for couples;
• from NOK 1.9M to NOK 21.5M — 1.0% in total (0.35% municipal plus 0.65% state);
• above NOK 21.5M — 1.1%.

The composition was recut — the municipal rate cut back from 0.525%, the state share raised — leaving the taxpayer's total unchanged. Valuation discounts soften the blow: shares and commercial property enter the base at 80% of value, a main home at 25% up to NOK 10M and at 70% of the value above that threshold, a second home in full.

Two 2026 novelties matter more than the rates. The tax point has moved to 31 December of the income year, which ends the old games with the date of departure. A deferral has also appeared: formuesskatt above NOK 30k may be spread over up to three years, but at 9% interest. The backdrop is familiar — in 2022–2023 Kjell Inge Røkke and dozens of wealthy Norwegians moved to Switzerland, most often to Lugano.

Switzerland

A cantonal net wealth tax exists everywhere, from ~0.1% in the central cantons to ~1% at the top in Geneva. This is deliberate architecture — restrained income tax plus a wealth tax of its own, and for foreigners the lump-sum regimes from the special tax regimes family on top.

The referendum of 30 November 2025 added confidence: a federal 50% levy on estates above CHF 50M was rejected. The status quo is stable, and Switzerland remains the principal harbour for those fleeing other countries' wealth taxes — compare the inheritance tax map.

France

LF 2026 — adopted on 2 February and promulgated on 19 February 2026 as LOI n° 2026-103 — left the taxation of personal wealth exactly as it was. The amendment introducing an impôt sur la fortune improductive passed the National Assembly by 163 votes to 150; during the navette the Senate replaced it with a different construction, and neither version made it into the final text. Décision n° 2026-901 DC of 19 February 2026 confirms this by omission: the Conseil constitutionnel examined articles 7, 8 and 11 and censured only paragraph III of article 69 as a cavalier budgétaire — the words "fortune improductive" appear nowhere in the decision.

The old IFI still applies: net real estate only, a €1,300,000 threshold as at 1 January 2026, articles 964–983 CGI, and the 75% plafonnement under article 979 CGI. Neither euro funds nor cash nor crypto-assets fall inside the perimeter. Works of art have sat outside IFI since its birth in 2018, so the ADAGP campaign reads as a fight against a bill that died of its own causes; the practical consequences for collections are in art tax planning.

What article 7 of LF 2026 did create is a tax that did not exist before — article 235 ter C CGI, the "taxe sur les actifs non affectés à une activité opérationnelle des sociétés holdings patrimoniales". Three conditions apply cumulatively: the market value of all the company's assets is at least €5,000,000; at least one individual holds 50% or more of the voting or financial rights; and passive income accounts for more than 50% of operating and financial receipts combined. The rate is 20% of the value of the taxable assets — against the fractions of a per cent normal for a wealth tax, a confiscatory level.

The perimeter is narrow and pointedly symbolic — biens somptuaires: hunting and fishing grounds, cars, yachts and aircraft for personal use, jewellery and precious metals, racing and show horses, wine and spirits for personal consumption, and residential premises over which the controlling owner has retained a right of use, including rent-free occupation and letting below market. The tax applies to exercices clos from 31 December 2026 onwards; it catches French companies subject to IS and foreign companies with at least one individual shareholder who is French tax-resident. That last clause is what makes the rule matter in practice: the move against luxury assets has been made at the level of holding structures, non-French ones included.

The Netherlands

Box 3 is legally an income tax and economically a wealth tax: 36% on the forfaitair rendement, a deemed return set by asset class. In 2021 and again in 2024 the Hoge Raad barred taxation of a return above the actual one, and taxpayers gained the right to prove their real result. The move to a tax on actual income — Wet werkelijk rendement — has passed the Tweede Kamer, with 2028 as the target start. Until then the regime runs on counter-evidence and recalculations.

The Rest of the World

A full-blown wealth tax outside that group of five is rare. Colombia has made its impuesto al patrimonio permanent; Argentina is phasing bienes personales down to token rates. Italy charges residents IVIE at 1.06% on foreign real estate and IVAFE at 0.2% on foreign financial assets — a quasi-wealth tax on portfolios moved abroad. Belgium withholds 0.15% a year on securities accounts with an average value above €1M.

Zucman's proposal for a 2% minimum on billionaires, discussed by the G20 in 2024, stayed on paper. While the global projects stall, the burden on the wealthy is migrating from broad direct taxes to targeted ones — surveyed in luxury taxes. Russia, the United States, the United Kingdom, Germany and the overwhelming majority of jurisdictions have no annual wealth tax at all, and that is the map's baseline.

Switzerland from the Inside

The formula is the same in every canton: taxable wealth is run through the basic-tax tariff (einfache Steuer) and the result is multiplied by the Steuerfuss, to which the canton, the district, the municipality and the parish each contribute. The spread between municipalities within a single canton reaches a factor of 1.7, so a cantonal rate quoted without the name of the municipality is useless.

Schwyz shows the mechanics most clearly: one law, a flat rate, and a bill that turns on nothing but the municipality. Wollerau gives 0.6‰ × 1.82 = 1.09‰, that is 0.109% of taxable wealth; the town of Schwyz, on the identical tariff, gives 0.6‰ × 3.11 = 1.87‰, or 0.187%. The famous "~0.1%" lives in Wollerau and Freienbach; extending it to the central cantons as a whole is wrong. Zug, at 2.0‰ in the top tranche with a cantonal 82%, produces 0.164% before any municipal supplement; Zurich, at 3.0‰ with a cantonal 95%, produces 0.285%. The Zug and Zurich tariffs are taken from the ESTV Kantonsblatt with Stand: September 2023, the Geneva and Schwyz ones from the February 2026 edition; check the tariff for the relevant year before running any calculation.

Geneva works on two storeys. On top of the basic barème sits the impôt supplémentaire under art. 59 al. 2 LIPP, and no cantonal centimes are charged on it: "Il n'est perçu aucun centime additionnel sur cet impôt supplémentaire sur la fortune". The limiter is the bouclier fiscal of art. 60 LIPP: wealth and income tax together with the centimes may not exceed 60% of net taxable income. The trap sits in the denominator — where the actual yield on the property is below 1% of net wealth, a theoretical 1% yield is substituted into the calculation. The owner of a low-yielding portfolio ends up with a cap computed on income he does not have.

Unlisted Shareholdings: KS 28

Shareholdings in companies without a stock-exchange quotation are valued under Kreisschreiben 28 SSK, current edition 12.2022. For trading, manufacturing and service companies the Praktikermethode applies: "Der Unternehmenswert ergibt sich aus der zweimaligen Gewichtung des Ertragswertes und der einmaligen Gewichtung des Substanzwertes" (RZ 34) — earnings value weighted twice, net asset value once, divided by three.

Holding companies, asset management companies and finance companies fall outside the formula: under RZ 38 their value is the pure Substanzwert. A personal holding structure cannot be written down through loss-making, because the earnings component simply does not apply to it. The year of incorporation and the start-up phase likewise go by net assets (RZ 32) until representative results appear.

The capitalisation rate under RZ 10 is built from the risk-free rate, a premium for non-listing risk and a 17.65% illiquidity uplift; it is published annually in the ESTV Kursliste and must be taken from there for the specific year — advisers' surveys diverge from one another by a full percentage point and a half. The 30% minority discount under RZ 61–64 is available for holdings of up to 50% of capital where there is no significant influence and no "adequate" dividend is paid, adequate meaning a yield at the level of the risk-free rate plus one percentage point.

The Lump-Sum Regime and Wealth Tax

Expenditure-based taxation replaces the wealth tax base while keeping the tax itself. Schwyz states the mechanics most precisely: § 15a Abs. 4 StG (SRSZ 172.200) sets the minimum base at "das 20-fache der Bemessungsgrundlage für die Aufwandbesteuerung beim Einkommen" — twenty times the income base. The greater of two figures is taxed: actual gross assets in Switzerland, or that twenty-fold minimum. Deductions are shut off entirely — "Es können keine Abzüge (Schuldenabzug und Sozialabzüge) vom steuerbaren Betrag geltend gemacht werden".

The arithmetic is direct: income base × 20 × 0.6‰ × Steuerfuss. On a base of CHF 600,000 the deemed wealth is CHF 12,000,000 and the Wollerau tax CHF 13,104 a year, whatever the real size of the portfolio. For a client with CHF 100M the regime saves an order of magnitude; for a client with CHF 10M the wealth component of the lump-sum tax costs more than the ordinary route. The multiplier is cantonal: the twenty-fold figure is confirmed for Schwyz, no equivalent published rule could be found for Zug, Geneva, Vaud or Valais, and "20×" cannot be carried across to them. The minimum income base is likewise set by the canton and should be checked for the year of the calculation. The general framework of the regime is in special tax regimes.

A €10M Bill

Assumptions: a single taxpayer with no children, €10,000,000 of net wealth, no asset qualifying for any exemption, income high enough that the income-based caps never bite, and no church tax. ECB rates as at 7 August 2026 are EUR/CHF 0.9347 and EUR/NOK 10.9750, giving CHF 9,347,000 and NOK 109,750,000.

The Madrid figure looks counter-intuitive against a 100% bonificación until the mechanics are unpacked. Cuota íntegra on the state IP scale over a base of 9,300,000 is €154,354; the ITSGF cuota is €122,908 (0% up to €3M, then 1.7% and 2.1%). Ley 12/2023 pares the Madrid bonus back to exactly the difference, €31,446, so the client pays the region €122,908 and the federal backstop is zeroed by the credit. The Catalan scale is the state scale multiplied by 1.05, which puts this base in the 2.205% band; the region collects more than the backstop would have taken, so ITSGF is nil here too. The gap between the two Spanish addresses on an identical fortune is €43,574 a year.

Norway comes out in two lines: 19,600,000 × 1.0% plus 88,250,000 × 1.1% = NOK 1,166,750. The 80% valuation discount on shares cuts the bill by €22,000 without changing a single asset in substance. The Swiss pole is a flat 0.6‰ on everything left after the CHF 125,000 deduction. Barcelona is 15.5 times more expensive than Wollerau on the same fortune — an intra-European spread available without a single offshore construction.

Mitigation Mechanics

The first layer was built in by the legislator: thresholds and allowances, the business-asset exemption — the Spanish empresa familiar, the Norwegian valuation discounts — and the income-based caps. In Spain the sum of wealth tax and income tax is capped at 60% of income, with a minimum 20% of the tax always payable; the French plafonnement holds the combined burden within 75% of income. Using these is basic hygiene, with no flavour of aggression about it.

The second layer is the lawful forks in the road. A change of residence changes everything: inside Switzerland the choice of canton moves the rate by multiples, and leaving Norway or Spain removes the tax altogether — but the price of departure is costed first, against the exit taxes overview. Asset structure works more subtly: shifting into exempt or discounted classes is lawful exactly as long as substance stands behind the form.

The third layer is the edge. Loans from your own company instead of distributions, "business" wrappers around passive portfolios, personal holding structures with no substance: for every one of these moves a recharacterisation rule has already been written. The two most popular storylines are taken apart below.

Empresa Familiar

The business-asset exemption under art. 4.Ocho Ley 19/1991 is the most powerful instrument on the whole map: it lifts IP and ITSGF at the same time, whereas a regional bonificación is no protection against the federal backstop. The conditions for holdings in entities (art. 4.Ocho.Dos):

• a holding of at least 5% individually, or at least 20% together with the family group — spouse, ascendants, descendants and collateral relatives to the second degree;
• actual exercise of management functions, "ejercer efectivamente funciones de dirección";
• remuneration for those functions exceeding 50% of total business, professional and employment income; where a family group is involved, it is enough that one member clears the threshold;
• the entity is not engaged in the management of movable or immovable property;
• the exemption is proportionate: it applies to the extent that the entity's assets are employed in economic activity.

For a sole trader (art. 4.Ocho, paragraph Uno) the key condition is softer: the activity must be "su principal fuente de renta".

The weight of the relief shows in the data: for Catalan taxpayers with more than €10M, business assets account for practically all exempt property. Everything else at that level is cosmetic. The mínimo exento under art. 28 is €700,000 where there is no regional rule. The límite conjunto under art. 31 cuts the IP cuota by at most 80% where IP plus IRPF exceeds 60% of the IRPF tax bases, so 20% of the tax is paid come what may. Art. 4.Ocho operates on a different scale: bringing €7M of our €10M under the exemption drops the Catalan bill from €166,482 to roughly €24,800 — a factor of 6.7, with no change of residence.

The construction breaks at two points. The first is who pays for the management: in judgment 200/2025 of 5 May 2025 the TSJ Islas Baleares accepted that the remuneration may be paid by another company in the group, "si bien tal previsión habrá de contenerse de forma expresa en la escritura de constitución o en los estatutos sociales", citing consulta vinculante DGT V0810-18. Without that wording in the constitutional documents the arrangement falls apart. The second is treasury balances: the Tribunal Supremo declined to strip financial assets out of the exempt portion automatically where they reflect ordinary liquidity-management needs, and placed the burden of proving excess on the tax authority. The citation details of that judgment differ between published summaries, so they should be verified on CENDOJ before being relied on in a dispute.

Compliance

Valuation is annual and follows local rules: cadastral and computed figures for real estate, quoted prices at the reporting date, formula values for unlisted holdings. Norway pre-fills the return from state registers, Spain requires Modelo 714 and, for ITSGF, Modelo 718, and France assembles the base through annexes to the income tax return.

Foreign assets are transparent: banks in more than a hundred jurisdictions send balances and income to the country of residence every year — the mechanics are in the CRS overview. Hiding a portfolio from a wealth tax today means criminal exposure, and the Spanish penalties under Modelo 720 stand as a vivid monument to that. Planning through opacity ended a decade ago.

Risks

Popular, and It Ends Badly

"Move to Madrid for the bonificación." A client with €12M shifts residence to Madrid: the regional tax is zeroed and on paper the saving runs to hundreds of thousands a year. The denouement: the federal ITSGF takes back exactly what the region gave up — 1.7/2.1/3.5% above €3M — and since Ley 12/2023 Madrid itself trims the bonificación by the amount of the backstop and collects it as regional IP. The saving collapses to almost nothing and the "temporary" tax has been extended with no end date; all that changes is the till the payment goes into.

"Loans from your own company instead of dividends." A Norwegian classic: the shareholder lives on loans from his AS, there are no dividends, and the wealth sits in shares carrying a valuation discount. The denouement: since 2015 Norwegian law recharacterises the arrangement for tax purposes — a loan to a personal shareholder is treated as a dividend at the moment it is advanced, at an effective rate of around 37.8%, plus assessments for earlier years once the tax authority unwinds the history. Cognate rules exist right across the map, so the technique dies the same death everywhere.

Sources

1. AEAT — Impuesto Temporal de Solidaridad de las Grandes Fortunas
2. Regjeringen.no — Prop. 1 LS (2025–2026), Chapter 1
3. LégiFiscal — PLF 2026 : nouvelle version de l'impôt sur la fortune adoptée au Sénat — an intermediate stage of the process; this version did not make it into law
4. ADAGP — Loi de finances 2026 : récapitulatif des mesures
5. Deloitte — Wet werkelijk rendement (box 3) aangenomen door Tweede Kamer
6. KPMG — GMS Flash Alert 2025-221: Norway Budget 2026
7. Conseil constitutionnel — Décision n° 2026-901 DC du 19 février 2026
8. Légifrance — CGI, taxe sur les actifs des sociétés holdings patrimoniales (art. 235 ter C)
9. Service-public.fr — IFI: threshold and perimeter (verified 06.03.2026)
10. ESTV — Kantonsblatt Schwyz (§§ 47–48 StG)
11. ESTV — Kantonsblatt Zug (§ 38 StG)
12. Kanton Schwyz — Steuerfusstabelle 2026
13. Kanton Schwyz — Merkblatt Besteuerung nach dem Aufwand (§ 15a StG)
14. SSK — Kreisschreiben 28: Bewertung von Wertpapieren ohne Kurswert (12.2022)
15. République et canton de Genève — Bouclier fiscal (art. 60 LIPP)
16. Kanton Zürich — Steuerfüsse 2026/2027
17. BOE — Ley 19/1991 del Impuesto sobre el Patrimonio (arts. 4.Ocho, 28, 30, 31)
18. Skatteetaten — Forskuddsutskrivingen 2026
19. ECB — Euro foreign exchange reference rates

Last reviewed: August 2026