Entity Setup
Entity Setup & Residency: The New Non-UK Domicile Regime and FIG
With the abolition of the old non-dom and domicile rules in April 2025, individuals resident in the UK must adapt to the new Foreign Income & Gains (FIG) regime. Here’s what entity-dependent individuals and advisors need to know.
By NomadicTax Research Team • 5-8 min read • March 11, 2026
## What Are the Key Changes?
- Effective from **6 April 2025**, the UK ended the traditional _non-UK domicile_ concept and replaced it with a **residence-based regime** for foreign income and gains. ([assets.publishing.service.gov.uk](https://assets.publishing.service.gov.uk/media/672105124da1c0d41942a8a8/Reforming_the_taxation_of_non-UK_individuals.pdf?utm_source=openai))
- Under the new **Foreign Income & Gains (FIG) regime**, **qualifying new residents** may enjoy 100% relief on eligible foreign income and gains during their first **4 years** of residence, provided they have been non-UK resident for the preceding 10 years. ([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))
- For **existing non-doms**, transitional arrangements include: rebasing of assets to 5 April 2019, a temporary 50% exemption on foreign income for 2025-26, and a Temporary Repatriation Facility (12% tax on overseas income gains 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))
## Implications for Entity Holders, Shareholders & Executives
- If you hold offshore companies, trusts or overseas assets as part of your compensation or control structure, you’ll need to rethink how foreign income and gains are taxed under the new regime.
- If your entity setup relies on the old domicile or remittance basis rules—e.g. trusts that kept income offshore to avoid UK tax—these features may now offer less advantage or incurring different tax charge.
- Individuals entering the UK (e.g. executives, entrepreneurs) may plan their arrival date, structure generational transfers, or asset location in light of benchmarks like 10 years non-UK residence to qualify for FIG fully.
## Actionable Strategies
1. **Review your structuring** — examine offshore entities, trusts, assets that generate foreign income/gains. Assess tax impact under FIG vs exposed under domicile regime.
2. **Take advantage of transitional relief** — if eligible, use the Temporary Repatriation Facility, asset rebasing, etc. to mitigate past exposure.
3. **Document residence status carefully** — track non-UK residence for 10 years prior; understand what constitutes ‘qualifying new resident’.
4. **Plan distributions and transfers** — consider timing of disposing assets or moving gains, especially before full exposure under the FIG regime.
5. **Engage with tax advice** — rules are complex; getting professional advice, especially around trusts, relocations or international income can save unexpected liabilities.
## Example Scenarios
- A US national moving to the UK in early 2025 with foreign rental income: under FIG they may claim relief in first four years so long as meeting criteria; asset gains if disposed could use rebased value from April 2019.
- A family trust set up abroad which used to pay minimal UK tax via remittance basis: under the new rules, beneficiaries resident UK will need to report global gains as they arise—trust distributions to UK-resident beneficiaries could be taxed on worldwide basis.
## Key Takeaways
- The new FIG regime leads to **much greater transparency** and earlier taxation of foreign income and gains.
- Transitional reliefs provide some cushion—but **understand the deadlines**.
- Residency history matters — count those non-UK years.
- Structuring entity setups (trusts, companies) to align with the new rules is essential to avoid surprise tax charges.
For digital nomads, asset holders, executives—this change is one of the biggest to cross-border taxation in the UK in recent years.