Entity Setup
Entity Setup & Domicile: Structuring for the New UK Non-Dom Regime
With the remittance basis gone, the residence-based regime requires strategic structuring of trust, entity and domicile to manage tax exposure of foreign income, gains and inheritance.
By NomadicTax Research Team • 7 min read • November 23, 2025
## New Non-Dom Reality
From **6 April 2025**, the UK replaces the non-UK domicile (non-dom) remittance basis with a **residence-based regime**. This means that most new UK residents will have foreign income and gains taxed in the UK unless they fall under specific transitional arrangements. Offshore trusts will be unable to shelter assets from Inheritance Tax (IHT) as before. ([gov.uk](https://www.gov.uk/government/publications/autumn-budget-2024-overview-of-tax-legislation-and-rates-ootlar/841ddc37-58e0-4d3f-9b53-123e8903d274?utm_source=openai))
## Entity Setup Strategies
### Trusts and Offshore Structures
- Trusts that once benefited from non-dom sheltering for IHT must be reviewed. Use of offshore trusts should be evaluated in light of the new IHT regime. ([gov.uk](https://www.gov.uk/government/publications/autumn-budget-2024-overview-of-tax-legislation-and-rates-ootlar/841ddc37-58e0-4d3f-9b53-123e8903d274?utm_source=openai))
- Consider restructuring entities into UK-registered trusts or entities if your long term aim is UK residence, to achieve transparency and easier compliance.
### Residency Considerations
- Establish tax residency timing carefully—if you expect to be UK resident from April 2025, foreign income or gains brought into remittance basis may not be sheltered afterward.
- Entities with foreign operations should manage profit repatriation carefully, especially given changes to foreign income rules under new non-dom regime.
### Inheritance and Asset Ownership
- Inherited pensions included in IHT from April 2027—holding pension assets via entities or planning inheritance via spousal transfers or lifetime gifts becomes more critical. ([gov.uk](https://www.gov.uk/government/publications/autumn-budget-2024-overview-of-tax-legislation-and-rates-ootlar/841ddc37-58e0-4d3f-9b53-123e8903d274?utm_source=openai))
- Business and agricultural property reliefs are being restricted: 100% relief for combined business/agricultural assets only on first £1 million, then 50%. Affects estates above this threshold. ([gov.uk](https://www.gov.uk/government/publications/autumn-budget-2024-overview-of-tax-legislation-and-rates-ootlar/841ddc37-58e0-4d3f-9b53-123e8903d274?utm_source=openai))
## Practical Example
- A non-UK domiciled investor setting up an investment entity should consider UK incorporation if significant gains or income will be remitted post-residency.
- A family with agricultural assets should consider transferring or using business combinations early to benefit from full relief up to £1 million.
## Checklist Before Entity Setup or Irreversible Moves
- Identify whether your foreign income/gains qualify under residence-based regime transitional rules.
- Check pension arrangements and how inheritance rules will apply to them soon.
- Choose entity domicile and legal structure in light of IHT, CGT, and non-dom law changes.
- Document all ownership and control details to satisfy compliance and reporting in new top-up tax, if applicable.
**Entity Setup Category**
TaxHome: UK
Author: NomadicTax Research Team
ReadTime: 7 min
Published: true