Digital Nomad
How the New Residence-Based Regime Affects International Professionals in the UK
The UK’s sweeping changes to the non-dom tax regime from 6 April 2025 brings significant implications for long-term non-residents, returnees, and global talent planning their relocations.
By NomadicTax Research Team • 5-8 min read • November 22, 2025
## What’s changed?
From **6 April 2025**, the UK is replacing the old **non-dom and remittance-basis rules** with a **residence-based system**. The key features include:
- A new **4-year Foreign Income and Gains (FIG) regime** for individuals who have been non-UK tax resident for at least 10 consecutive years before becoming resident. During their first 4 years of UK residence, FIG arising in those years won’t be taxed and can be brought into the UK tax-free. ([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) retained and simplified—but limited to the first **3 tax years** of UK residence for those opting into the 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))
- Abolition of the remittance basis: from 6 April 2025, non-doms no longer get tax advantages simply by virtue of having a domicile outside the UK. FIG will be charged on an arising basis, except as preserved under transitional or FIG reliefs. ([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))
- A **Temporary Repatriation Facility (TRF)** for tax years 2025-26 and 2026-27 allowing individuals who previously used remittance basis to bring pre-6 April 2025 foreign income or gains into the UK for a special reduced rate (12%, then 15% in the final year). ([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))
- Inheritance Tax (IHT) changes underway: the system is shifting from domicile-based to residence-based, with proposed rules around long-term residence, tail periods after leaving the UK, and general alignment of estates including non-UK assets. ([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))
## Who will be most impacted
| Group | Immediate effect | Long-term considerations |
|---|---|---|
| Individuals becoming UK tax resident from abroad after 10 years non-UK residence | Can use the FIG regime for first 4 years, bring in foreign income/gains tax-free during that period. |
| Non-doms resident in UK already but not qualifying for FIG regime | Loss of remittance basis; transitional reduced tax rate on foreign income for 2025-26; full arising basis from then on. |
| Trustees / beneficiaries under non-UK trusts | The protection on trust income/gains ends. Trust income/gains from 6 April 2025 taxed on settlors/transferors if not within FIG regime. |
## Practical examples
- **Example 1:** Jamie moves back to the UK in 2025 after 12 years abroad. Jamie qualifies for the FIG regime, so income from foreign dividends in 2025–26 and 2026–27 (while under FIG) won’t be taxed—even if repatriated. If income arises through a trust established before 2025 but distributions after, it may still matter whether the settlor qualifies. ([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))
- **Example 2:** Inna has lived in the UK for 6 years by April 2025 but had been non-resident prior to that. She does not meet the 10-year non-residence criterion for FIG. She loses remittance basis on 6 April 2025, will be taxed on her worldwide income/gains as they arise. For 2025-26 she enjoys a 50% reduction on foreign income under the transitional rule. ([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))
## What to do now: Planning tips
1. **Assess your residence history**: Do you meet the 10-year non-UK tax residence requirement? That determines whether you qualify for FIG.
2. **Consider timing**: If you're moving to UK soon, moving after 6 April 2025 but with long non-UK residence opens FIG benefits; missing the date may leave you exposed under the new “arising” rules.
3. **Evaluate use of trusts tightly**: Trusts get less shelter; distributions and gains might be taxed more aggressively unless you're in the FIG regime.
4. **Inheritance planning revisited**: The shift to residence-based IHT means owning non-UK property can attract IHT based on your years of UK residence. Wills, trusts, assets need review.
5. **Seek professional advice**: Especially for mixed residence history, complex assets abroad, or plan to move back to the UK.
## Summary
The UK’s 2025 regime overhaul means the era of non-dom status with generous remittance rules is over. What matters now is **residency**, and the new FIG framework grants temporary relief to eligible individuals but comes with trade-offs. For anyone with foreign income, substantial overseas assets or trust relationships, early mapping against the new rules is essential.