UK non-domiciled status, and the remittance basis that went with it, ended on 6 April 2025. Two centuries of domicile-based taxation were replaced by a residence test. If you are still planning around domicile, you are planning around a rule that no longer exists.
What replaced it: the 4-year FIG regime
New arrivals qualify for the Foreign Income and Gains (FIG) regime if they have been non-UK resident for the 10 consecutive tax years immediately before arriving. Where that test is met:
- Foreign income and foreign gains are exempt from UK tax for four tax years of residence.
- The money can be brought into the UK freely — no remittance trap, no clean-capital gymnastics.
- Overseas Workday Relief is available for the same four years, subject to an annual cap.
The trade-off: claiming FIG treatment means giving up the personal allowance and the CGT annual exempt amount for that year. For most people in scope this is trivial arithmetic.
After four years you are taxed on worldwide income and gains like any other UK resident. There is no extension, no remittance basis charge, no long-stay option. The regime is a runway, not a home.
Inheritance tax is now about residence
IHT moved to a long-term resident (LTR) test on the same date. You are an LTR — and within UK IHT on worldwide assets — once you have been UK-resident in at least 10 of the previous 20 tax years.
The tail matters as much as the entry:
| UK residence in the last 20 years | IHT tail after leaving |
|---|---|
| 10–13 years | 3 years |
| 14 years | 4 years |
| 15 years | 5 years |
| each further year | +1 year |
| 20 years | 10 years |
Excluded-property trusts settled before the reform no longer give permanent protection: assets in them fall within the settlor's IHT scope while the settlor is an LTR. Gift-with-reservation and the relevant property regime apply accordingly.
The Temporary Repatriation Facility
Anyone who previously used the remittance basis can bring historic foreign income and gains onshore at a flat rate through the TRF:
- 12% for 2025/26 and 2026/27
- 15% for 2027/28
- The facility then closes
Designated funds can be remitted at any time thereafter without further UK tax. For long-term remittance-basis users sitting on decades of unremitted income this is the single largest planning item on the table — and the 12% window closes at the end of the 2026/27 tax year.
Trust protections
The protected settlement regime is gone. From 6 April 2025 foreign income and gains arising in a settlor-interested non-resident trust are taxed on the settlor as they arise, where the settlor is UK-resident and outside the FIG window. Trusts still do useful work on succession, asset protection and governance. They no longer do the tax work they used to.
The realistic options
1. Stay and pay. For many, the UK remains where family, business and schooling are. Four years of FIG, then normal UK taxation, with planning focused on pensions, business asset structuring and IHT reliefs.
2. Use the four years properly. Realise gains, restructure holdings, reset base costs and remit capital while it is free to do so. The window is short and it does not come back.
3. Leave before the LTR clock runs. Departure only works when it is real: the Statutory Residence Test counts days, ties, workdays and accommodation, and the IHT tail follows you for three to ten years regardless. Common destinations are the UAE, Italy's flat-tax regime, Greece, Portugal, Switzerland's lump-sum arrangement and Malta — each with genuinely different substance demands.
4. Restructure the estate. Where an IHT tail is unavoidable the work shifts to what sits inside the estate: business relief, life cover written in trust, and non-UK-relieved pension provision such as a QNUPS.
Timing points not to miss
- The 12% TRF rate ends after 2026/27. Designations take planning and valuation work; leaving it to the final quarter rarely goes well.
- FIG eligibility depends on 10 clear non-resident years. A single UK-resident year inside that window disqualifies you entirely.
- Split-year treatment and treaty tie-breakers change the arithmetic on arrival and departure. Model them before you move, not after.
How we work on this
We map your residence history, test FIG and LTR status on the actual dates, quantify the TRF decision, and set out the leave-or-stay comparison with numbers rather than slogans. Fixed scope, director-signed, no commissions.
Related reading: QNUPS explained · QROPS in 2026
General information as at 2026. UK tax rules change; take advice on your own facts before acting.