PPLI Portability: Moving Countries with an Existing Policy

Read millionaire migration figures as estimates

Henley & Partners' 2025 migration series, sourced to New World Wealth, labels 142,000 as a provisional global figure. Its definition concerns individuals who relocate and remain for more than six months. It is not a count of households, completed policy transfers or failed financial structures.

The figures above come from the publisher's 2025 release. Net migration subtracts departures from arrivals; a net outflow is not the total number leaving. These historical forecasts do not establish the eventual 2025 result or the amount of wealth transferred.

The report's methodology defines millionaires as individuals with at least USD 1 million in liquid investable wealth. It combines a private database with other sources, including applications, registers and moving-company information. Henley advises on residence and citizenship. These are commercial research estimates, not an official population census or evidence that PPLI improved migrants' outcomes.

The 2026 score measures a different question

Henley's June 16, 2026 release reports Wealth Mobility Competitiveness Scores of 85.3 for the UAE, 79.5 for Singapore, 75.8 for New Zealand and 74.3 for the Cayman Islands. The framework methodology explicitly distinguishes these directional scores from actual migration flows and forecasts. They also do not certify an insurer, insurance statute or individual tax plan.

Its accompanying measurement discussion explains the difficulty of identifying departures and defining wealthy migrants. Do not turn an attractiveness score into a prediction that a particular family will relocate, or a claim that families who move once are statistically more likely to move again.

Compare the family's reasons and actual tax position

Employment, schools, relatives, business access, safety and residence rights belong in the family's decision alongside tax. Record which considerations matter to this household. A country-level estimate cannot prove why an individual left the UK, China, Germany or France, or whether moving was financially beneficial.

The UAE government's personal income tax guidance states that it does not levy income tax on individuals. That needs context: the Federal Tax Authority identifies corporate-tax rules for natural persons carrying on business, including the AED 1 million turnover threshold and exclusions for defined wages and investment income. Other countries may retain taxing rights.

Italy has an elective substitute-tax regime for qualifying new residents under Article 24-bis of its income tax code. The Italian Revenue Agency's guidance should be checked for the relevant arrival date and tax year. A regime's existence does not establish eligibility, cover every kind of income or determine the treatment of a proposed insurance contract.

What a move can change in a directly held portfolio

Start with an inventory of accounts, pensions, funds, companies, trusts, insurance and real estate. For each, identify its owner, tax basis, unrealized gain, currency, restrictions and expected cash needs. Then compare treatment before and after the proposed residence change.

• Funds: determine whether the destination applies foreign-fund or anti-deferral rules. For example, a U.S. person with an interest in a passive foreign investment company may face tax and filing obligations described in the Form 8621 instructions. Not every foreign fund or country follows the same system.
• Pensions: check recognition, contribution and withdrawal rules, and any applicable treaty. Do not assume that all foreign pensions lose their treatment on arrival.
• Trusts and companies: examine classification, management, attribution, distributions and reporting. An unchanged document does not establish an unchanged tax result.
• Property: check taxation where the property is located and in the owner's residence country, together with available treaty relief or credits. Physical location does not necessarily give one country exclusive taxing rights.

The alternatives are broader than liquidating everything or accepting a mismatch. They may include retaining an asset, changing a service provider, making a permitted election, modifying an arrangement or selling selected holdings. Each alternative needs its own tax and cost comparison. An insurance proposal should be tested against those options.

What the UK changes actually mean

Four-year FIG relief has eligibility and claim conditions

On April 6, 2025, the UK's four-year foreign income and gains regime replaced the remittance basis. A qualifying new resident must be within the first four UK-resident tax years following at least ten consecutive tax years of non-UK residence. Relief requires a claim for eligible income or gains. Claiming also removes specified allowances.

The period is not four years from the date of a claim. An arrival before April 2025 can have fewer years left, and unused years cannot simply be saved for later. The regime does not exempt all foreign receipts. HMRC sets out the relevant categories in RFIG45100. Foreign-policy chargeable event gains require their own analysis; the insurer's foreign address does not make them eligible for FIG relief.

Inheritance tax can continue after departure

For events from April 6, 2025, the general long-term residence test for overseas assets is at least ten UK-resident tax years within the preceding twenty. HMRC's IHTM47020 explains that, subject to the applicable conditions, departing long-term residents can remain within scope for three to ten tax years. Transitional cases and later returns require separate calculation.

This test operates independently of FIG relief. Ownership, trusts, the nature of the assets and the date of a transfer or death also matter. A foreign policy does not by itself remove inheritance-tax exposure. HMRC's long-term resident guidance also identifies circumstances in which trustees need to consider charges.

A continuing insurance policy can still attract annual tax

The UK's personal portfolio bond rules can impose an annual charge where the policy allows selection of personal assets beyond the permitted categories. HMRC's IPTM3600 gives a private trading company as an example and explains the insurance-year test. The charge can arise even though the policy continues and no withdrawal is made.

Helpsheet HS321 separately explains chargeable events and taxation of gains as income. Review policy selection rights, underlying assets, ownership and any available relief before relying on UK tax deferral. Neither a pre-arrival issue date nor an offshore issuer settles those questions.

The useful lesson is to test the law currently applying to each person and contract. There is no evidence here that every family relying on the former remittance basis lost its arrangements, or that every family using a trust, company or policy achieved a better result.

What must be portable in the insurance arrangement?

An insurer can own investments supporting the policy while the policyholder holds contractual rights. A change in the policyholder's residence need not, by itself, require every underlying asset to move. Whether the existing arrangement can continue depends on the contract, local law and the providers involved. Obtain answers to four separate questions:

1. Contract: will coverage continue, and does a residence change require notification, an endorsement or another action?
2. Servicing: can the insurer accept further premiums and provide the requested transactions in the new residence? Can the current manager and custodian continue?
3. Tax: how will each relevant country classify the policy, its owner and its income, payments and death benefits?
4. Investments: can the existing holdings and selection rights remain, or must they change before a deadline?

A carrier's written service confirmation and a tax adviser's analysis serve different purposes. Ask both to identify the policy version, assumed residence dates and limitations. Our globally mobile executives guide provides related planning context.

U.S. arrival requires more than a foreign insurance label

U.S. tax residence can arise under the green-card or substantial-presence tests, with exceptions and elections that require attention to dates. Review the IRS Tax Guide for Aliens before assuming that immigration paperwork or a planned moving date determines the first taxable day.

The policy analysis includes Section 7702, applicable separate-account diversification under Treasury Regulation 1.817-5, and the actual investment-control facts addressed in Revenue Rulings 2003-91 and 2003-92. A foreign contract is not automatically U.S.-qualifying. Separately assess funding history, modified endowment contract status, access to cash and estate inclusion where relevant.

Separate family residence, policy ownership and issuer jurisdiction

Map all three. The family may live in one country, a trust or company may own the policy in another, and an insurer may issue it from a third. Identify the insured and beneficiaries as well. A list of passports is not a substitute for determining tax residence and relevant citizenship-based obligations.

U.S. citizens and resident aliens generally remain subject to U.S. tax on worldwide income while abroad, as explained in IRS Publication 54. Moving to Dubai therefore does not, by itself, remove a U.S. person's tax obligations.

For the issuer, review the actual licensed entity, governing law, policyholder rights, account segregation, solvency information, servicing permissions, dispute process and applicable compensation arrangements. Do not choose a policy from a country's migration ranking. Compare the documents behind proposals from Bermuda, the Cayman Islands, Luxembourg or Singapore on the same requirements. None is universally suitable for a geographical category of families.

If another move is plausible, test named destinations as scenarios. Record unresolved countries as unresolved. No issuer can guarantee that today's laws or provider permissions will remain unchanged for a generation.

Creditor protection is a separate legal review

Ask which statute protects which interest against which creditor. Segregation from an insurer's general account is different from an exemption protecting the policyholder's rights from personal creditors. Trust ownership adds questions about control, transfers, enforcement and recognition abroad. It does not make the arrangement immune to court orders or later legislation.

Review the governing documents with counsel in relevant jurisdictions, including existing or foreseeable claims and any applicable transfer-avoidance rules. Our cross-border asset protection guide and asset protection research distinguish these issues. Obtain the actual legal basis for any protection claimed in a proposal.

Check exit taxes and reporting even if the contract stays

There is no universal rule that an insurance policy prevents an exit-tax event. U.S. Section 877A expatriation rules, for example, concern specified citizenship relinquishments and terminations of long-term resident status, not every physical move. For covered expatriates, the general mark-to-market regime treats property as sold, with statutory exceptions and special rules. Notice 2009-85 expressly addresses valuation of an interest in life insurance.

Analyse departure-country charges on policy rights as well as directly held assets. Also consider continuing source-country taxation, temporary non-residence rules where applicable and the UK's inheritance-tax residence rules. Confirm whether a proposed surrender, assignment or replacement creates its own tax event.

Update the insurer's residence and tax-identification records. Review institutional CRS or FATCA reporting separately from the owner's returns. The IRS Form 8938 and FBAR comparison identifies foreign cash-value insurance as potentially reportable under both regimes, subject to their different filer, threshold and other requirements. See our PPLI reporting and transparency review for the wider reporting map.

Build a documented review before changing residence

The following is a proposed review method, not a statutory timetable or an assurance of approval. Start when a move becomes a realistic possibility. Set deadlines from the actual residence rules, policy anniversary, notice periods, underwriting requirements and asset liquidity.

For example, a family considering a UK move might obtain confirmation that coverage can continue but discover that investment-selection rights require review under the personal portfolio bond rules. That is a conditional continuation decision, not an automatic endorsement of the policy. The record should identify any changes needed, their deadline and their cost.

Price the possibility that the move never happens. A new policy still has insurance charges, administration costs, investment expenses and restrictions. Existing cover may have surrender costs or be difficult to replace on equivalent terms. Use actual proposals and the PPLI costs and economics framework; do not assume that optionality is free.

Keep domestic property and other assets outside the proposed arrangement in the same overall review. The aim is a coherent plan for the whole balance sheet, with exceptions visible. Our jurisdiction research supports comparison, while the wealth preservation hub connects ownership, succession and ongoing oversight.

Questions about PPLI portability

Can I keep a PPLI policy when I move abroad?

Possibly. Check the policy's residence-change provisions and obtain written confirmation from the insurer about continued coverage, premiums and servicing. Separately review the destination's tax treatment, investment restrictions and reporting. An unchanged contract can have a different tax result.

Does a portable policy avoid exit tax?

No blanket exemption follows from portability. Departure rules may apply to policy rights as well as other assets, and surrendering or replacing the policy can create a separate event. The countries, taxpayer status, dates and ownership determine which rules require review.

Does the UK's four-year FIG regime make a foreign policy tax-free?

No. FIG relief has residence, income-category and claim conditions. Policy chargeable event gains and personal portfolio bond rules require separate analysis. A foreign issuer or a policy purchased before arrival does not establish an exemption.

Which jurisdiction is best for a mobile family's policy?

There is no universal answer. Compare the actual issuer, contract, protection rules, permissible services, costs and treatment in the family's relevant countries. A country's migration score or favorable personal tax regime does not establish that a particular policy is suitable.