Non-doms and the Foreign Income and Gains regime: what changed on 6 April 2025

The remittance basis was abolished from 6 April 2025. For the 2025/26 tax year and later, UK residents can no longer choose to be taxed only on foreign income and gains they bring into the UK. The rules for earlier years, up to 2024/25, still apply, which matters for past remittances and for the Temporary Repatriation Facility. Everyone resident now is taxed on the arising basis unless the FIG regime applies.

Under the remittance basis, foreign income and gains were taxed only when brought to the UK, and long-term users paid an annual charge. The FIG regime instead gives a full exemption on qualifying foreign income and gains for the first four years of UK residence, and the funds can be brought here freely. It is only available to those with ten prior years of non-residence, and it is temporary.

Only if you were non-UK resident for at least ten consecutive tax years immediately before the year you became UK resident, and you are within your first four years of residence. Long-term residents who arrived long ago will not qualify. HMRC's guidance allows those whose four-year period began before 6 April 2025, from 2022/23 onwards, to use the regime for the remaining years.

The Temporary Repatriation Facility, or TRF, lets certain former remittance basis users pay a flat charge on designated pre-6 April 2025 foreign income and gains, rather than taxing them at full rates if remitted. The charge is 12% for designations made in respect of 2025/26 and 2026/27, and 15% for 2027/28. The money does not have to come to the UK to be designated.

You must be UK resident in the tax year of designation, have been taxed on the remittance basis for at least one earlier tax year, even without a claim, and hold qualifying overseas capital to designate. Non-residents cannot designate. A spouse or child cannot designate for someone else, and trustees are not listed as eligible. Personal representatives can designate for amounts the person received before death.

The designation is made in your Self Assessment return, with the deadline being the first anniversary of 31 January after the end of the tax year of designation. For 2025/26, that is 31 January 2028, for 2026/27 it is 31 January 2029, and for 2027/28 it is 31 January 2030. Because the 12% rate ends with 2026/27, the tax year in which you designate drives the cost.

Be careful. Paying the charge from pre-6 April 2025 foreign income or gains held overseas is safe only if that amount has been designated. Otherwise, bringing the money to the UK is an ordinary remittance taxed at normal rates, and HMRC has no exemption for payments sent directly to it. Foreign tax credits are also not available against designated amounts, which are taken net of foreign tax.

Rebasing lets some former remittance basis users treat certain foreign assets as acquired at their 5 April 2017 value for capital gains tax, so that only growth after that date is taxed on sale. HMRC's policy paper describes it as available to current and past remittance basis users. Detailed conditions apply, including who held the asset and when claims were made, so check it before you sell anything.

Employment income is dealt with separately. Overseas Workday Relief can apply to the part of employment income for duties performed outside the UK, for four years from arrival, and from 6 April 2025 it is capped at the lower of £300,000 or 30% of total employment income. Employees no longer need to keep the pay overseas. Other foreign income is dealt with under the FIG claim.

In each year you claim, you lose the personal allowance, the capital gains tax annual exempt amount, the blind person's allowance, the married couple's reductions, the transferable allowance and some life insurance relief. You also cannot claim foreign income or capital losses, or foreign tax credit relief, on the income covered by the claim. The decision to claim is therefore made yearly, on the numbers.

You claim in your Self Assessment return, using the foreign pages, for each tax year and each source. The SA109 residence pages record that you are claiming. A separate claim is needed every year, and unused years cannot be carried forward. The claim deadline is the first anniversary of 31 January following the tax year, so for 2025/26 the deadline is 31 January 2028.

Yes. The relief only covers qualifying foreign income and gains. UK salary, UK rental profits, UK dividends and gains on UK assets are taxed in the usual way. Some foreign income is also excluded, which HMRC calls disqualified income, such as certain pension income and some trust-related income. We check each source before you decide on the claim.

From the fifth tax year, you are taxed on worldwide income and gains as they arise, whether or not you bring the money to the UK, with foreign tax credit relief where it applies. The four years do not restart if you leave and return. You would need another ten consecutive tax years of non-residence. Planning for year five, such as realising gains earlier, is common.

The old protection for foreign income and gains in settlor-interested trusts is not available to those who are not qualifying new residents. Trustees and settlors need to review who is taxed on what, and the TRF can apply to unattributed amounts in trusts. Trusts also face changes to inheritance tax, because excluded property status now depends on the settlor's long-term residence.

Deemed domicile for tax purposes has gone. Long-term residence now determines inheritance tax exposure instead. For people who were deemed domiciled on 30 October 2024 and were not UK resident in 2025/26, the transitional rules allow them to remain long-term UK resident until the start of their fourth year of non-residence. The details depend on your history.

Not automatically. Leaving can reduce income and gains tax, but the inheritance tax tail, UK property and the cost and family effects of a move all matter. Some people decide to stay, use the Temporary Repatriation Facility and simplify. Others leave. We model each route, including what it means for your wider family and businesses, before you commit.

Tax year 2026/27 is the last in which the TRF charge is 12%, rather than 15%. Review which pre-April 2025 foreign income and gains you hold and what you plan to remit. Consider capital gains tax rebasing on assets you may sell, check trusts and update your inheritance tax plan. Delay can be costly, so book an early review.