Digital Nomad
Digital Nomads Navigating UK’s Offshore & Trust Income Rules
Understanding recent changes in UK rules on trusts, foreign income and gains—and what digital nomads need to know to stay compliant without overpaying tax.
By NomadicTax Research Team • 5-8 min read • March 9, 2026
## What Has Changed for Trusts and Foreign Income
From 6 April 2025, UK rules on domicile and foreign income/gains (“FIG”) have been overhauled. The **remittance basis and protection for non-domiciled individuals and deemed domiciles** have ended—now it’s a residence-based tax regime. ([gov.uk](https://www.gov.uk/hmrc-internal-manuals/trusts-settlements-and-estates-manual/tsem4705?utm_source=openai))
UK resident settlors of trusts (where they or their spouse/partner may benefit) are now taxed on **all income arising under the settlement** as it arises, including foreign income, **regardless of when the trust was created**. Eligible individuals may still claim relief under the 4-year FIG regime. ([gov.uk](https://www.gov.uk/hmrc-internal-manuals/trusts-settlements-and-estates-manual/tsem4705?utm_source=openai))
## Key Implications for Digital Nomads
| Situation | What You Need to Know |
|---|---|
|You lived abroad, now UK resident | Pre-6 April 2025 FIG accumulations may be subject to tax under the new TRF (Temporary Repatriation Facility) if you now benefit. ([gov.uk](https://www.gov.uk/hmrc-internal-manuals/trusts-settlements-and-estates-manual/tsem4705?utm_source=openai))|
|You receive income or gains via offshore trust | Expect that income may be taxed differently. All income under certain trusts is taxed as it arises. Declaration obligations and matching rules may apply. ([gov.uk](https://www.gov.uk/hmrc-internal-manuals/trusts-settlements-and-estates-manual/tsem4705?utm_source=openai))|
|You’ll benefit from overseas work | Overseas Workday Relief (OWR) eligibility now depends on **residence** rather than domicile. Relief may be available if in the FIG regime. ([assets.publishing.service.gov.uk](https://assets.publishing.service.gov.uk/media/672105124da1c0d41942a8a8/Reforming_the_taxation_of_non-UK_individuals.pdf?utm_source=openai))|
## Practical Steps & Planning Tips for Digital Nomads
1. **Review your residency status** right away—residence, not domicile, is now central. Consider where you spend days and your connections to the UK.
2. **Identify foreign income and gains** that were held offshore—including trust income—and assess whether these will be taxed under new rules.
3. **Use the FIG regime**: If you qualify, you may get relief on foreign income/gains during your first 4 years of UK residence.
4. **Document carefully**: keep records of when income or benefits from trusts arise, and what you receive and when. The “settlements legislation” includes matching rules and reporting obligations. ([gov.uk](https://www.gov.uk/hmrc-internal-manuals/trusts-settlements-and-estates-manual/tsem4705?utm_source=openai))
5. **Review international work**: if earning overseas income from employment, check the availability of OWR under the residence-based test.
## Example Scenario
> **Case**: Ana, a remote worker who moved to the UK on 1 January 2025 and controlled a trust set up by her parents in 2010. Under old rules, the trust’s foreign income remained offshore and didn’t trigger UK tax unless remitted. Under new rules, **all income under that trust arising after 6 April 2025** will be taxed as it arises. Ana may claim FIG regime relief for up to four years if eligible.
## Actionable Insights for Nomads
- Conduct a **full audit** of all offshore structures and foreign gains and compare old vs new tax exposure.
- Update trust agreements if possible, or align benefits to reduce ongoing tax costs.
- Prepay or plan income timing where possible before new rules hit to smooth exposure.
- Use professional advice: trust and international tax specialists are essential in these cases.
By staying informed of the post-2025 rules, digital nomads can avoid surprises and align their structures to minimise tax costs within the new UK landscape.