The UK's centuries-old "non-dom" regime ended on 6 April 2025. In its place sits the Foreign Income and Gains (FIG) regime, which provides a four-year exemption from UK tax on foreign income and gains for new UK residents. The transition has been the most consequential change for internationally mobile clients in living memory.
What changed
Under the previous remittance basis, individuals who were UK resident but not UK domiciled could elect each year to pay UK tax only on foreign income and gains that were "remitted" to (brought into) the UK. The system favoured the very wealthy, with charges of £30,000 or £60,000 a year for long-term residents, but it kept enormous amounts of foreign wealth outside UK tax.
From 6 April 2025, residence-based taxation applies. The remittance basis is gone, the concept of domicile is removed from the income tax and CGT codes, and a new four-year FIG exemption applies to qualifying new residents.
The four-year FIG regime
For individuals who have been non-UK resident for at least 10 consecutive tax years before becoming UK resident, the FIG regime provides:
- Complete exemption from UK income tax on foreign income for the first four years of UK residence.
- Complete exemption from UK CGT on disposals of foreign assets for the first four years.
- No requirement to keep the money offshore — funds can be brought to the UK without triggering UK tax (unlike the old remittance basis).
- Loss of the personal allowance and CGT annual exempt amount in years where FIG is claimed.
After the four years end, worldwide income and gains are taxed in the UK in the normal way for as long as the individual is UK resident.
The transitional rules — important if you were a non-dom before April 2025
Existing non-doms received several transitional reliefs:
- Temporary Repatriation Facility (TRF): a reduced tax rate (12% for 2025/26 and 2026/27, 15% for 2027/28) on remittances of historic foreign income and gains, encouraging onshore deployment of previously protected funds.
- Rebasing of foreign assets: qualifying individuals could elect to rebase certain foreign assets to their 5 April 2017 value, capping the historical CGT exposure on disposals.
- Transitional first-year exemption for 2025/26: 50% reduction in foreign income tax for individuals who could not access the four-year FIG (e.g. those who had already used some of the eligibility window).
Inheritance tax — also residence-based
From 6 April 2025, IHT exposure is determined by residence rather than domicile. Individuals become subject to IHT on worldwide assets after 10 years of UK residence in the previous 20 tax years, with a 10-year "tail" once they leave the UK. For long-term UK residents previously protected by non-dom status, the IHT exposure on global wealth is now real and material.
Practical impact for our Dubai clients
Many PushDigits clients move between Dubai and London. The new rules require very careful arrival and departure planning:
- Arrival in the UK: confirm that you have been non-resident for 10 consecutive tax years to access the FIG regime. Track the start date carefully — the four-year clock is unforgiving.
- During FIG years: structure investment portfolios to maximise foreign income that benefits from FIG (subject to the loss of personal allowance and AEA).
- Pre-departure planning: understand the IHT 10-year tail before leaving — the tax does not simply switch off on the day you board the plane.
- Property and trust structures set up under the previous regime need a complete review. Many former excluded property trusts are now within scope of IHT.
The Statutory Residence Test — more important than ever
Because everything now turns on residence rather than domicile, the Statutory Residence Test (SRT) is the single most important set of rules for internationally mobile clients. Day-counting, ties tests, exceptional circumstances, and split-year treatment all require careful tracking. We use specialist day-tracking tools for clients who split time between jurisdictions.
Planning opportunities in 2026 and 2027
- Use the TRF window — the 12% rate available in 2025/26 and 2026/27 is significantly below normal UK rates. Remitting historic wealth at this rate may make sense even where the funds would otherwise have stayed offshore.
- Time investment realisations within the FIG window to crystallise foreign gains tax-free.
- Review existing settlor-interested trusts — these are now within scope of UK tax once the settlor has used four years of FIG.
- Plan property purchases with the SDLT non-resident surcharge in mind alongside FIG eligibility.
How PushDigits supports international clients
With offices in London and Dubai, our team works closely with clients moving between the UK and the Gulf. We provide pre-arrival reviews, FIG year structuring, TRF analysis, residence tracking, and pre-departure planning. The advice has to be tailored — these rules do not have shortcuts.
If you are currently UK-resident as a former non-dom, or you are planning to move to the UK in the next 24 months, get in touch for a confidential international tax review. The decisions you make now will define your UK tax position for the next decade. Read about our cross-border tax planning service.