On 26 March 2026 the UN Committee of Experts on International Cooperation in Tax Matters discussed the workplan for producing guidance on taxation of high-net-worth individuals. The relevant subcommittee presented its planned workstream.
There is already a UN Handbook on Wealth and Solidarity Tax, approved in 2025. The subcommittee will draft further guidance on the issues. The guidance will focus on high-net-worth individuals (HNWIs) and tax transparency issues. The aim of the subcommittee is to produce a Handbook on Taxation of HNWIs. This will contain practical, policy oriented and administratively feasible guidance for developing countries.
The subcommittee will examine a broad range of instruments; look at domestic and international policy and coordination; examine administrative aspects; and consider transparency and information exchange. The guidance will look at strategies used by HNWIs, and the measures that should be taken to tackle these strategies. Measures taken at international level need to be examined. Case studies and examples will be used to enhance the explanations.
The guidance will also analyse the structure within the tax administration and look at the advantages of setting up specialised units to deal with HNWIs. Tax administration staff could build up expertise in this area of taxation and gain the necessary experience for effective administration. The benefits must be weighed against the related costs of setting up a unit, by tax administrations that may lack the necessary resources.
An important consideration in taxing HNWIs is the data that may be available to identify the wealth of HNWIs. Measures for the international exchange of information will be important in tracking the assets held worldwide by the HNWIs. There are also economic challenges to introducing a wealth tax, and political considerations in obtaining approval for the measures. It will be necessary to liaise with the subcommittees dealing with tax and AI, tax and gender and the UN Model.
Participants in the meeting noted that there are challenges for developing country tax administrations in exchanging information. Various types of assets held by HNWIs are difficult to tax owing to the mobility of assets and of people. If countries take unilateral measures on taxation of HNWIs, this can lead to capital flight, as people and assets may move between countries.
A concerted approach is therefore needed. International measures will only be effective if there is global participation. The measures required involve strengthening tax administration and increasing the use of new technology such as AI. The tax administration needs the capacity to detect and tax HNWI assets and income. The international exchange of information is important in achieving this, but confidentiality of taxpayer data is an issue.
Another issue is identifying the ultimate owner or beneficiary of assets. The guidance must go beyond theory, and the subcommittee could prepare a roadmap on how to integrate the tools to identify the ultimate beneficial owners. Shares are mobile and can change hands, so immovable assets may be quite mobile if they are owned by a legal entity.
Tools for taxing HNWIs should include anti-avoidance legislation, and the use of exit taxes to collect tax from mobile individuals. An individual minimum income tax could be considered. The measures could be coordinated by a dedicated unit in the tax administration.
