Digital Nomad
Digital Nomads and the New UK Residence-Based Tax Regime: What Non-Domiciled Individuals Need to Know in 2025
With the UK abolishing the remittance basis and introducing a residence-based foreign income and gains regime from April 6, 2025, digital nomads must carefully assess how these changes affect offshore income and trust distributions.
By NomadicTax Research Team • 5-8 min read • November 23, 2025
## Introduction
Starting 6 April 2025, the UK is bringing in sweeping changes that **end the remittance basis** of taxation for non-UK domiciled individuals and replace it with a **4-year foreign income and gains (FIG) regime**.([gov.uk](https://www.gov.uk/government/publications/changes-to-the-taxation-of-non-uk-domiciled-individuals/technical-note-changes-to-the-taxation-of-non-uk-domiciled-individuals?utm_source=openai)) These reforms will significantly impact digital nomads and long-term international residents. In this article, we unpack how the changes operate, their consequences, and actionable strategies for nomadic individuals.
## Key Changes to the UK’s Non-Domicile Regime
- The remittance basis rules—whereby non domiciled UK residents paid UK tax only on income remitted to the UK—are abolished from 6 April 2025.([gov.uk](https://www.gov.uk/government/publications/tax-changes-for-non-uk-domiciled-individuals/reforming-the-taxation-of-non-uk-domiciled-individuals?utm_source=openai))
- A new **4-year foreign income and gains (FIG) regime** is introduced for individuals who become UK tax residents after at least 10 preceding tax years outside the UK, allowing them to bring foreign income/gains into the UK tax-free for up to four tax years.([gov.uk](https://www.gov.uk/government/publications/changes-to-the-taxation-of-non-uk-domiciled-individuals/technical-note-changes-to-the-taxation-of-non-uk-domiciled-individuals?utm_source=openai))
- Overseas Workday Relief (OWR) remains for the first three UK residence years, simplified in eligibility.([gov.uk](https://www.gov.uk/government/publications/changes-to-the-taxation-of-non-uk-domiciled-individuals/technical-note-changes-to-the-taxation-of-non-uk-domiciled-individuals?utm_source=openai))
- Foreign income or gains arising in non-resident trusts are taxed on the settlor or transferor (if resident more than four tax years), similar to UK domiciled individuals. Distributions from trusts which were non-resident before 6 April 2025 may have transitional treatment.([gov.uk](https://www.gov.uk/government/publications/changes-to-the-taxation-of-non-uk-domiciled-individuals/technical-note-changes-to-the-taxation-of-non-uk-domiciled-individuals?utm_source=openai))
## Implications for Digital Nomads
- **Tax on worldwide income**: Many who previously benefitted from remittance treatment will under the new rules face tax on foreign income and gains as they arise—regardless of whether they bring money into the UK.([gov.uk](https://www.gov.uk/government/publications/changes-to-the-taxation-of-non-uk-domiciled-individuals/technical-note-changes-to-the-taxation-of-non-uk-domiciled-individuals?utm_source=openai))
- **Trust distributions**: Funds or gains held offshore in trust structures may now trigger tax obligations for settlors or beneficiaries.([gov.uk](https://www.gov.uk/government/publications/changes-to-the-taxation-of-non-uk-domiciled-individuals/technical-note-changes-to-the-taxation-of-non-uk-domiciled-individuals?utm_source=openai))
- **FID regime eligibility**: To access the 4-year FIG relief, an individual must be UK resident after at least 10 non-UK years. Nomads who have recently returned may or may not qualify. Timing is crucial.([gov.uk](https://www.gov.uk/government/publications/changes-to-the-taxation-of-non-uk-domiciled-individuals/technical-note-changes-to-the-taxation-of-non-uk-domiciled-individuals?utm_source=openai))
## Practical Strategies Before and After April 2025
| Stage | Action Item | Why It Matters |
|---|---|---|
| Before April 6, 2025 | **Rebase assets** held personally on 5 April 2019 if taxed under remittance basis, to minimize unrealized gains.([gov.uk](https://www.gov.uk/government/publications/changes-to-the-taxation-of-non-uk-domiciled-individuals/technical-note-changes-to-the-taxation-of-non-uk-domiciled-individuals?utm_source=openai)) | Helps reduce exposure as future gains are taxed on arising basis. |
| | Review offshore income flows/trust distributions now under remittance basis, assess expected exposure under new regime. | Evaluate whether income should be brought to UK earlier or managed offshore under new rules. |
| After April 2025 | Opt into FIG regime if eligible (first four years of UK residence after 10 years abroad). | Offers full relief on offshore income and gains during that period. |
| | Organize trust structures carefully or consider winding them down. | To avoid surprise tax liability on trust income/gains. |
| | Keep detailed documentation of any foreign income/gains, trusts, dates of residence. | Essential for accurate tax reporting under new regime. |
## Examples
- **Case A – Eligible nomad**: Jane moves to the UK on 6 April 2025 after 11 years abroad. She opts into FIG. Her foreign rental income earned abroad before remittance into UK is tax-free during her first four UK tax years. On her fifth UK year, all foreign income and gains as they arise are taxable.
- **Case B – Not eligible**: Bob moved to UK in 2023 after 10 years abroad. He does **not** qualify for FIG until 2025-26. His foreign income in 2024-25 may still be taxed under arising basis without remittance relief.
- **Case C – Trust exposure**: Carla has distributions from a family trust based outside UK. Under new rules, she may be taxed on the income in trust depending on settlor status or residency, even if funds aren’t remitted.
## Action Checklist
- Consult with UK tax adviser before 6 April if you have offshore income or trust interests.
- Map your years of absence/residence to determine FIG eligibility.
- Review offshore assets held on 5 April 2019; consider gains and benefit of possible rebasing.
- Update tax structure of businesses and roles held abroad.
- Track and record all foreign income/gains, including dates and nature.
## Conclusion
The 2025 changes to UK non-domicile taxation mark one of the most significant shifts in foreign income and trust taxation in decades. For digital nomads and global citizens, understanding the fine print—eligibility, residency duration, trust ties—is critical. With careful planning before the April deadline, many can mitigate exposure and take advantage of the new regime. Knowledge and timing will pay off.