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 NomadicTax Research Team • 5-8 min read • June 28, 2026
## 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](https://assets.publishing.service.gov.uk/media/672105124da1c0d41942a8a8/Reforming_the_taxation_of_non-UK_individuals.pdf?utm_source=openai)) 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](https://www.gov.uk/government/publications/summary-of-tax-update-2026-simplification-modernisation-and-fairness/tax-update-2026-simplification-modernisation-and-fairness-summary?utm_source=openai))
## 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](https://www.gov.uk/government/publications/summary-of-tax-update-2026-simplification-modernisation-and-fairness/tax-update-2026-simplification-modernisation-and-fairness-summary?utm_source=openai))
## 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.