What changed on 6 April 2025 for UK "non-doms"?
UK Non-domA tax status that taxed some residents only on foreign income they brought into the country. The UK's version was replaced from April 2025. status, and the Remittance basisBeing taxed on foreign income only when you bring it into the country, rather than when you earn it. that went with it, ended on 6 April 2025. Non-dom status was the old rule that let people with a foreign "permanent home" pay UK tax only on foreign money they brought into the UK. A residence test has replaced two centuries of taxing people by domicile. If you're still planning around domicile, you're planning around a rule that no longer exists.
What replaced it: the 4-year FIG regime
If you're a new arrival to the UK, you get four years where your foreign money is mostly outside UK tax, provided you've been away long enough first. The regime is called the Foreign Income and Gains (FIG) regime. You qualify if you were 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, with no remittance trap and no need for clean-capital planning.
- 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 Capital gains tax (CGT)Tax on the profit when you sell something, such as shares, property or a business, for more than you paid. annual exempt amount for that year. (The personal allowance is the slice of income everyone gets tax-free. The CGT annual exempt amount is the same idea for capital gains, meaning profit when you sell an asset.) For most people in scope this is trivial arithmetic.
After four years you're taxed on worldwide income and gains like any other UK resident. There's no extension, no remittance basis charge and no long-stay option. Think of the regime as a runway rather than a home.
- 1Before you arriveBe non-UK residentyou need 10 consecutive tax years of non-UK residence immediately before arriving
- 2Years 1 to 4FIG appliesforeign income and gains are exempt from UK tax, and you can bring the money in freely
- 3After year 4Normal UK taxyou're taxed on worldwide income and gains like any other UK resident, with no extension
Inheritance tax is now about residence
Inheritance tax (Inheritance tax (IHT)Tax on what you leave behind when you die. In the UK it now follows long-term residence rather than domicile.) is the tax on what you leave when you die, and it now turns on how long you've lived in the UK, not where your "permanent home" is. It moved to a Long-term UK residentThe UK status that decides whether your worldwide estate is in scope for UK inheritance tax, based on how many past years you were UK resident. (LTR) test on the same date. You're an LTR, and within UK IHT on your worldwide assets, once you've been UK-resident in at least 10 of the previous 20 tax years.
The tail matters as much as the entry. Even after you leave, UK IHT can follow you for a while.
| 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. (The settlor is the person who put the assets into the trust.) Gift-with-reservation and the relevant property regime apply accordingly.
Where are the grey areas?
The rules above are clear on paper. The points below are where they bite hardest or depend on judgement, so know them before you act.
- Leaving the UK to escape the long-term resident clockarguable
Why it's greydeparture only works when it's real, because the Statutory Residence Test counts days, ties, workdays and accommodation, and the IHT tail follows you for three to ten years regardless
What it could meanif the move doesn't hold up you could stay within UK tax, and the IHT tail applies even if it does
- Moving abroad on arrival or departure datesarguable
Why it's greysplit-year treatment and treaty tie-breakers change the arithmetic on arrival and departure, so the result depends on your exact dates
What it could meanthe wrong dates could change what's taxed, which is why you model them before you move, not after
- Relying on pre-reform trusts for IHT protectionsettled
Why it's greyexcluded-property trusts settled before the reform no longer give permanent protection, and assets fall within the settlor's IHT scope while the settlor is an LTR
What it could meanassets you thought were outside UK IHT could be inside it
Grey areas turn on the details: where you live, how the money moves and what paperwork you keep. On a free 30-minute call we look at your own situation and tell you plainly how strong your position would be, before you commit to anything.
The Temporary Repatriation Facility
If you used the remittance basis in the past, you can bring old foreign income and gains into the UK at a flat low rate, but only for a limited time. The scheme is the Temporary Repatriation Facility, or TRF. The rates are:
- 12% for 2025/26 and 2026/27
- 15% for 2027/28
- The facility then closes
Designated funds can be remitted at any time afterwards without further UK tax. For long-term remittance-basis users sitting on decades of unremitted income, this is the largest planning item on the table. The 12% window closes at the end of the 2026/27 tax year.
What happened to trust protections?
Trusts no longer shelter foreign income and gains from UK tax the way they used to. 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. (A settlor-interested trust is one where the person who set it up, or their family, can still benefit.)
Trusts still do useful work on succession, asset protection and governance. They just don't do the tax work they used to.
What are your realistic options?
There are four broad routes, and the right one depends on where your life actually is. Here they are side by side:
| Option | Best fits if… | The catch |
|---|---|---|
| 1. Stay and pay | Family, business and schooling are in the UK | Normal UK tax after the four FIG years |
| 2. Use the four years properly | You can act within the window | The window is short and doesn't come back |
| 3. Leave before the LTR clock runs | You'll really move your life | The IHT tail follows you for three to ten years |
| 4. Restructure the estate | An IHT tail is unavoidable | Work shifts to what sits inside the estate |
1. Stay and pay. For many, the UK remains where family, business and schooling are. That means 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's free to do so. (Resetting base cost means updating the starting value used to work out future gains.) The window is short and it doesn't come back.
3. Leave before the LTR clock runs. Departure only works when it's real. The Statutory Residence Test (the UK's day-counting test for whether you're resident) 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 expects a different amount of real presence and activity from you, which is what 'substance' means here.
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.
What are the timing points not to miss?
Three dates and tests can cost you money if you leave them late.
- The 12% TRF rate ends after 2026/27. Designations take planning and valuation work, and 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 treatmentA UK rule that can split the tax year in two when you arrive or leave, so you're only taxed as UK resident for part of it. treatment and treaty tie-breakers change the arithmetic on arrival and departure, so 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, work out the TRF decision in pounds, and set out the leave-or-stay comparison with numbers. 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.
