The Future of Taxation's Pillar Three

Beyond Pillar One and Pillar Two, a new concept is beginning to surface in global tax policy discussions: an informal “Pillar Three”—focused not on multinational corporations, but on private wealth and mobile individuals.

In this episode, we explore how this emerging framework is being articulated, drawing on insights highlighted by Fernando Del Canto, and why it may represent the next frontier in international taxation.

🔎 What a “Pillar Three” Could Look Like1️⃣ Minimum Global Wealth Taxes

A central feature of this emerging pillar would be a coordinated approach to taxing accumulated wealth, rather than focusing exclusively on annual income.

Key implications include:

• Net wealth as a standalone tax base

• Reduced reliance on realization events

• Greater scrutiny of asset holdings across borders

This would mirror the logic of Pillar Two—but applied to individuals instead of corporations.

2️⃣ Harmonised Inheritance and Succession Rules

Another likely component is greater alignment of inheritance and gift tax frameworks across jurisdictions.

The objective would be to:

• Reduce arbitrage between national systems

• Limit avoidance through migration shortly before death

• Improve transparency around cross-border estates

This would not require identical tax rates—but rather converging rules on scope, reporting, and connecting factors.

3️⃣ Anti–“Tax Nomad” Measures

A Pillar Three framework would almost certainly include stronger measures targeting highly mobile individuals whose primary motivation for relocation is tax avoidance.

Expected features include:

• Enhanced center-of-life and economic substance tests

• Coordinated exit taxes and trailing tax liabilities

• Reduced effectiveness of short-term or purely formal relocations

The emphasis shifts from where someone claims to live to where their life and wealth are actually anchored.

🎯 Why This Matters

Pillar Three would represent a philosophical shift in global taxation:

• From income → to wealth

• From corporations → to individuals

• From formal residence → to economic reality

While still conceptual, the direction of travel is clear: private wealth and mobility are becoming systemic policy targets, not edge cases.

🎧 Key Takeaway

Pillar Three is not yet law—but it reflects a growing consensus that global tax coordination cannot stop at corporations.

For HNWIs, families, and advisors, this signals:

• Increased long-term scrutiny of wealth structures

• Fewer safe havens based on mobility alone

• The need for planning grounded in substance, transparency, and durability

The era of global tax reform may be entering its third phase.