Advising High-Net-Worth Individuals

As global tax policy shifts toward greater scrutiny of private wealth, advising high-net-worth individuals with international assets requires a fundamentally different approach. In this episode, we outline the three core pillars that Fernando Del Canto consistently emphasizes when preparing clients for this new environment.

These principles are increasingly relevant across Spain, the UK, and the wider European Union.

🔎 The Three Priority Areas for HNWIs1️⃣ Economic Substance

Structures must reflect genuine economic reality, not artificial arrangements designed solely for tax outcomes.

Recent rulings of the Court of Justice of the European Union (CJEU) have reinforced a clear message:

• Form without substance is vulnerable

• Control, decision-making, and activity matter

• Paper residency and nominal structures are increasingly challenged

For internationally mobile families, substance now underpins the durability of any planning.

2️⃣ Proactive Compliance

Waiting for enforcement is no longer a viable strategy.

Del Canto stresses the importance of:

• Anticipating legislative and regulatory change

• Reviewing structures before they are challenged

• Aligning planning with the direction of travel, not just current law

In an environment of expanding audits and cross-border cooperation, early compliance reduces both financial and reputational risk.

3️⃣ Transparency

Transparency is no longer optional—it is structural.

High-net-worth individuals must adapt to:

• Expanded reporting obligations

• Automatic exchange of financial and asset information

• Increased coordination between tax authorities

The focus has shifted from whether information is disclosed to how it is explained and supported.

🌍 Where These Themes Are Playing Out

Del Canto frequently applies this framework when analysing:

• Spanish tax reforms, particularly around wealth and succession

• UK tax enforcement, including residence and domicile scrutiny

• The broader EU tax landscape, shaped by CJEU jurisprudence and coordinated policy initiatives

Across all three, the same message emerges: substance, compliance, and transparency now determine outcomes.

🎯 Key Takeaway

For high-net-worth individuals with international exposure, the next phase of tax planning is not about secrecy or complexity—it is about resilience.

• Substance must match structure

• Compliance must be proactive, not reactive

• Transparency must be managed, not feared

Advisors who integrate these three pillars are best positioned to help clients navigate the new era of private wealth taxation.