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OSLO: The irony was almost perfect: super-rich people who fled from one country for Switzerland due to tax, threatened to leave Switzerland due to tax.

“I think many will move,” said Kjartan Aas, a Norwegian millionaire who now lives in Switzerland, ahead of a referendum to impose inheritance tax on the wealthiest. Tord Kolstad, another millionaire who left Norway due to the left-wing government’s tax policies, told Bloomberg: “Even though I’m very happy in Switzerland, I would have to reconsider if this goes through.”

In the end, the crisis was averted – nearly four-fifths of Swiss voting in the referendum rejected the initiative, dashing proponents’ hopes that a close result could spur similar proposals in the low-tax Alpine country in the years ahead.

But the worries of so many billionaires and millionaires – expressed publicly or privately – exposed a certain truth: If wealth preservation is the sole or main determinant of where you live, there is always a risk of an inconvenient law change causing you to move, and maybe move again.

GENEROUS TAX RESIDENCY LAWS

Take the case of John Fredriksen. Born in Norway, Fredriksen is one of the main figures in the global shipping industry, with interests spanning everything from tankers and dry-bulk vessels to offshore oil services and fish farming.

He left Norway in 1978 for the United Kingdom, and later renounced his Norwegian citizenship for a Cypriot one. But earlier this year, as the UK’s Labour government abolished the so-called non-dom status and explored the possibility of a wealth tax, Fredriksen was off again, this time for the United Arab Emirates.

“It is beginning to remind me more and more of Norway. Great Britain has gone to hell, like Norway … The whole Western world is on its way down,” Fredriksen told financial website E24. He even had the temerity to say, while in Norway: â€śI try to avoid Norway as much as I can.”

One issue is that many countries have generous allowances for how long people can spend there without becoming a tax resident.

Willy Michel, a Swiss pharmaceuticals billionaire, told the local newspaper Neue Zurcher Zeitung before the referendum that he and his wife would leave if the initiative were adopted. “We can still spend 180 days a year in Switzerland. We also have a residence in Mallorca, something in Piedmont, so even now we’re only here half the time,” he added.

Then there’s Lars Seier Christensen, the co-founder of Denmark’s Saxo Bank, a major shareholder in the football team FC Copenhagen and an investor in many of the Danish capital’s best restaurants, including Alchemist. He lives in Switzerland but can spend up to half of the year in his homeland – “that is more than enough”, he once told me jovially.

TARGETING THE SUPER-RICH

Faced with ageing populations and growing budget deficits, many countries are finding the rich a suitable target to try to balance the economic books. The end of non-dom status in the UK – under which UK residents who declared their permanent home as being overseas could avoid paying UK tax on foreign income and gains – led to a slew of the super-rich moving out.

Italy, which has attracted its fair share of the wealthy due to its flat-tax regime for foreign income, has announced it plans to increase the levy by 50 per cent to €300,000 (US$350,000) per year from 2026. Michel had touted the current €200,000 figure as a potential attraction for him, compared to Switzerland.

That contrasts with other financial centres, especially in the Middle East and Asia, which are trying to win over the super-rich through tax concessions and light-touch regulation. Abu Dhabi, Dubai, Hong Kong and Singapore are all trying to attract wealthy family offices.

“For me, it’s a question of where you really want to live. If you would be happy in Dubai, then go for it, but for me it would be far too sterile. I’m happy with where I am, even if I’m not always happy with the tax and regulation in Europe,” one of Europe’s richest people told me a few years ago.

Aas has floated the idea of moving to Sweden from Switzerland due to its lack of inheritance tax and proximity to Norway – a turnaround from the 1970s when effective tax rates in Sweden occasionally went above 100 per cent of income and forced out entrepreneurs such as Ingvar Kamprad to the Alpine country.

Switzerland’s reputation as a reliable country for the wealthy may still be intact after the failed referendum. But the vote showed how ready some of the super-rich are to move again if tax laws threaten their wealth.