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Digital Nomad

Digital Nomad Life under the New FIG and SRT Rules: Moving, Working & Taxing Post-2025

With the abolition of the remittance basis and new Foreign Income & Gains rules, this article walks digital nomads through how UK tax residence, treaty use, and tax timing work now.

By Nomadic Tax Institute research team · 5-8 min read · Created

Foreign Income and Gains (FIG) Regime: What’s New

From 6 April 2025, the UK ended the traditional remittance basis system and introduced the Foreign Income and Gains (FIG) regime for non-UK domiciliaries. Now, income and gains earned abroad are taxed on a arising basis—not just when funds are brought into the UK.(assets.publishing.service.gov.uk) This means timing and understanding of when you became UK resident matters a lot.

Statutory Residence Test (SRT) & Split Year Treatment

  • The Statutory Residence Test (SRT) still governs your residency status—it looks at days in UK, connections, ties, etc. |
  • Split-year treatment may apply if you arrive or leave partway through a tax year. This often gives partial UK tax liability. |
  • Examples:
    • If you spend fewer than 91 days in the UK and keep fewer than 30 workdays, you may avoid full tax residence. |
    • Arriving in October 2025—first half tax year non-resident, then resident for remaining months, applied via split year. |

Double Taxation Agreements (DTAs) & Reverse Hybrids

  • Consult UK DTAs to reduce double taxation—many treaties provide credit relief. |
  • Recent consultations are looking at reverse hybrid entities, including US LLCs, which might have been taxed at effective rates over 75% due to mismatches. Reforms aim to remove these double-tax scenarios.(gov.uk)

Practical & Tactical Steps for Digital Nomads

  1. Map your physical locations to SRT days precisely. Poor tracking could result in unexpected UK residence status. |
  2. Identify global income sources now. Under FIG, foreign gains you used to hold offshore get taxed when they arise. |
  3. Check treaty provisions. If your country of residence / work has a DTA, know what reliefs or tax credits are available. |
  4. Plan finances for UK arrival. If moving to the UK, try to minimise transition income before becoming UK resident so exposure starts cleanly. |
  5. Cover National Insurance obligations. Being non-resident doesn’t always mean NI exemption; arrangements exist for some overseas directors and mobile individuals.(gov.uk)

Example Scenarios

  • A remote worker based in Dubai earning foreign-sourced consulting income now must include it in their UK tax returns once resident—even if the money remains offshore. |
  • A US LLC owner entering a reverse hybrid entity may see double taxation due to current mismatches—if reforms pass, those effects could be mitigated. |

Summary

The FIG regime and changes around DTAs & reverse hybrids have reshaped how digital nomads are taxed in the UK. To optimise your tax position, track residency carefully, anticipate arising-basis taxation of foreign income, and stay alert to upcoming policy reforms reducing unfair double taxation.

Sources

Existing article citations

Structured source metadata was not recorded for this historic item. Links below were cited in the article body.

Reforming_the_taxation_of_non-UK_individuals.pdf (assets.publishing.service.gov.uk)

tax-update-2026-simplification-modernisation-and-fairness-summa… (www.gov.uk)