Capital Positioning in an Era of Increasing Control
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Assessment of jurisdictional stability and regulatory trends for long term capital holders.
Governments worldwide are expanding their capacity to monitor, tax, and restrict capital movement. This brief outlines verified developments and assesses jurisdictional options for investors prioritising stability, predictability, and legal clarity.
The environment for internationally mobile capital has shifted materially since 2022. Three structural forces are converging simultaneously: the extension of automatic tax information exchange into digital assets, the proliferation of exit taxes across OECD member states, and a formal recalibration of IMF policy toward capital flow management measures. For long-term capital holders and their advisers, the question is no longer whether these trends affect planning outcomes. It is which jurisdictions remain structurally outside their reach.
The Regulatory Landscape: 2026
Three converging trends are reshaping the environment for mobile capital:
TRANSPARENCY EXPANSION
The OECD Common Reporting Standard (CRS) now covers electronic money products, central bank digital currencies, and indirect crypto investments. Automatic exchange of crypto asset data commences 2027 under the Crypto-Asset Reporting Framework (CARF), which went live across 48 jurisdictions on 1 January 2026. Collection of transaction-level data begins now; first exchanges between tax authorities are scheduled for 2027.
The practical effect is that offshore capital is now significantly more visible to home country tax authorities than at any previous point. Crypto asset service providers exchanges, custodians, wallet operators are required to collect user tax identification numbers and report transaction data annually. The EU implemented CARF through DAC8, effective 1 January 2026, with mandatory reporting to member state revenue authorities by September 2027. The structural consequence is that anonymity between asset classes is no longer a viable planning assumption for clients in CRS and CARF jurisdictions.
Source: OECD CARF Monitoring and Implementation Update, November 2025. EU DAC8 Directive (EU) 2023/2226, October 2023.
The Netherlands approved the Wet werkelijk rendement box 3 on 12 February 2026, passing with 93 votes in the House of Representatives. The legislation imposes a 36% tax on unrealised investment gains on stocks, bonds, and cryptocurrencies, effective January 2028. Notably, the Dutch Finance Minister indicated a partial reversal within two weeks of passage, citing investor pressure, though the Senate debate remains pending. Norway tightened exit taxation in 2024 to 37.8% on gains above NOK 3 million, eliminating the previous five year deferral window. The UK ended its non domicile regime from 6 April 2025. France came within one vote of adopting citizenship based taxation Amendment I-CF380 was rejected by 131 votes to 132 on 25 October 2025.
The pattern across OECD Europe is consistent: governments are extending the reach of investment taxation while simultaneously building the cross border reporting infrastructure that makes informal minimisation strategies obsolete. Belgium introduced capital gains taxation on financial assets from 1 January 2026 a historic first for that jurisdiction. Denmark is evaluating unrealised gains treatment for crypto. The direction of travel across the continent is toward broader tax bases, higher rates on mobile capital, and longer exit tax tails. Clients who were planning on a five to ten year horizon in 2020 are operating in a materially different compliance environment today.
Sources: IMI Daily (February 2026); citizenx.com analysis (March 2026); IFC Review (February 2026); Bloomberg Tax (February 2026).
CAPITAL FLOW MANAGEMENT
The IMF formally recognises capital flow management measures (CFMs) as legitimate policy tools under its 2022 Institutional View Review and the 2023 Guidance Note on the Liberalization and Management of Capital Flows. The 2022 review expanded the conditions under which preemptive CFMs are considered appropriate including before a capital surge materialises, rather than only in response to one. This is a significant departure from the prior framework, which treated capital controls as a last resort tool.
Several OECD member states have strengthened beneficial ownership registers, real property foreign ownership restrictions, and financial intelligence reporting obligations in the 2023 to 2026 period. These measures create friction in capital movement that was not present in prior planning cycles. A 2026 IMF Working Paper introduced the FinOpen index tracking capital flow management intensity across 193 countries from 1996 to 2022, noting significant intra year shifts that standard indices miss. The practical implication for capital holders is that regulatory friction is not a theoretical risk it is a demonstrably increasing feature of the jurisdictional landscape across the developed world.
Sources: IMF Policy Paper 2022/008; IMF Guidance Note 2023/055 (doi.org/10.5089/9798400261053.007); IMF Working Paper 2026/021.
Jurisdictional Risk Assessment
The table below compares four commonly referenced jurisdictions across the dimensions most material to long-term capital positioning: the presence or absence of capital controls, assessed geopolitical risk as of 2026, and current structural status. These dimensions are distinct from tax efficiency metrics and reflect the structural stability criteria increasingly prioritised by globally mobile investors and their advisers.
Risk assessments here reflect demonstrated, not modelled, conditions. The Dubai elevation from low to assessed as requiring reassessment follows documented events in March 2026. The Malta improvement reflects post 2023 FATF compliance remediation. Singapore and New Zealand retain low geopolitical risk assessments based on geographic position, neutral foreign policy, and absence of capital control history
| Jurisdiction | Capital Controls | Geopolitical Risk | 2026 Status |
| New Zealand | None since 1985 | LOW | Stable |
| Singapore | None (sector limits only) | LOW | Stable |
| Dubai / UAE | None | ELEVATED | Reassess |
| Malta | EU framework | LOW | Improved |
DUBAI UPDATE · MARCH 2026
Following regional military conflict, Dubai’s real estate index fell approximately 30% in two weeks. Markets suspended trading. The DIFC building was struck by drone. Investors should update risk models to reflect demonstrated, not theoretical, geopolitical exposure.
Dubai’s FATF greylisting from 2024 remains under review. UAE CARF reporting is scheduled to commence in 2028, one year after the initial 48-jurisdiction cohort. These combined factors warrant formal reassessment of Dubai as a primary capital base for risk-averse long-term holders.
New Zealand: What Changed in 2025 and 2026
Two structural developments in 2025 are directly relevant to capital holders evaluating New Zealand that are not widely covered in general jurisdiction comparisons.
First, New Zealand launched its Depositor Compensation Scheme (DCS) on 1 July 2025 , the first deposit insurance framework in the country’s history, protecting eligible depositors up to NZD 100,000 per institution under the Deposit Takers Act 2023. New Zealand was previously one of very few OECD countries without such a scheme. The DCS is funded by levies on deposit takers, managed by the Reserve Bank, and aligns New Zealand with FDIC (US), FSCS (UK), and APRA (Australia) standards. For capital holders banking in New Zealand, this closes a structural gap that existed in prior assessments of the jurisdiction.
Second, the Reserve Bank of New Zealand completed its 2025 Review of Key Capital Settings, announcing final decisions on 17 December 2025. The review recalibrated capital requirements introduced under the 2019 Capital Review, reducing common equity requirements across the system by approximately NZD 5 billion while maintaining system resilience. Updated Banking Prudential Requirements take effect from 1 October 2026, with full implementation of the Deposit Takers Act framework by December 2028. The RBNZ has explicitly targeted alignment with Australian Prudential Regulation Authority (APRA) settings, reducing trans-Tasman banking risk for holders operating across both jurisdictions. Taken together, the DCS launch and the 2025 capital recalibration represent the most substantive upgrade to New Zealand’s financial system regulatory architecture in a generation timed precisely when capital holders are reassessing jurisdictional risk frameworks globally.
Sources: RBNZ Depositor Compensation Scheme (rbnz.govt.nz/dcs); RBNZ 2025 Review of Key Capital Settings, announced 17 December 2025; interest.co.nz capital review analysis, December 2025.
- Deposit insurance from 1 July 2025. NZD 100,000 per depositor per institution, automatic, government-backed, funded by levy on deposit takers. First such scheme in New Zealand history. Closes the last major gap in NZ depositor protection relative to OECD peers.
- Banking capital recalibration 2025 to 2028. RBNZ December 2025 decisions modernise capital rules, reduce system-wide common equity requirements by NZD 5 billion, introduce more granular risk weights, and align with APRA settings. Updated BPRs in force October 2026.
- NZ-UAE trade agreement in force. Comprehensive Economic Partnership Agreement came into force August 2025. Eliminates tariffs on nearly all NZ exports to UAE and includes investment protection provisions — relevant for Gulf-based clients considering NZ as a second jurisdiction.
- Overseas investment liberalisation in progress. Overseas Investment Act amendment bill before Parliament as at April 2026, streamlining consent process for foreign investors. The government has signalled a continued shift toward enabling inbound investment rather than restricting it.
- No capital gains tax under current government. The incumbent National-led coalition has ruled out a broad CGT. The opposition Labour party announced a limited CGT proposal in October 2025 targeting commercial and residential property (excluding family homes, farms, shares), with any implementation not before July 2027 at earliest and requiring an election win. No CGT exists today.
- CARF reporting alignment underway. New Zealand has provided public updates indicating movement toward CRS 2.0 schema and CARF implementation, consistent with OECD timelines. NZ is expected in the 2028 cohort for first exchanges — giving new arrivals operating under the Transitional Residency Exemption a material window before digital asset reporting commences.
KEY TAKEAWAY
The safe havens of the last decade are under pressure. What matters now is not where taxes are lowest, but where capital can move freely, property rights are protected, and the rules have stayed stable. That is a shorter list than it used to be.
Sources
IMF Guidance Note on Capital Flows (2023) imf.org →
OECD CARF Monitoring and Implementation Update (November 2025) oecd.org →
NZ Government Securities Overview 2025/26 treasury.govt.nz →
WJP Rule of Law Index: New Zealand (2024) worldjusticeproject.org →
Tax Foundation: Wealth Taxes in Europe (2025) taxfoundation.org →
IMF Institutional View Review on Capital Flows (2022) imf.org →
Chambers and Partners: Investing In New Zealand 2026 practiceguides.chambers.com →
KPMG: Taxation of International Executives, New Zealand (January 2026) kpmg.com →
RBNZ: Depositor Compensation Scheme rbnz.govt.nz →
RBNZ: 2025 Review of Key Capital Settings (December 2025) rbnz.govt.nz →
This briefing is for informational purposes only and does not constitute legal, tax, or investment advice. Data verified as of April 2026.