Digital Nomad
Navigating the New Residence-Based Regime for Non-UK Domiciled Individuals
Since April 2025, UK non-dom rules have transformed—this article explores the residence-based Foreign Income and Gains regime, Temporary Repatriation Facility, and how globally mobile individuals should adapt.
By NomadicTax Research Team • 5-8 min read • April 5, 2026
## From Domicile to Residence: What’s Changed
The old concept of domicile in UK tax law has been abolished for income and gains for non-UK domiciled individuals since **6 April 2025**. Under the new system, a **Foreign Income and Gains (FIG)** regime applies to those becoming UK tax residents after at least 10 years abroad. ([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))
Under FIG, qualifying individuals:
* Pay **no UK tax** on foreign income and gains in their first **four tax years** of UK residence, provided they had 10 years of non-UK tax residence prior.
* Continue to be taxed on UK source income in the normal way.
* Are subject to transitional arrangements—like allowing re-basing of assets to 5 April 2019 value, or using a **Temporary Repatriation Facility (TRF)** to bring in pre-6 April 2025 foreign income/gains at a reduced rate. ([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 & Globally Mobile Impacts
Globally mobile employees (working partly or fully abroad, or moving between countries) need to understand how their employment income and remittance-based reliefs now fit into FIG. Every country left or joined might affect tax liabilities. ([gov.uk](https://www.gov.uk/government/publications/globally-mobile-employees?utm_source=openai))
If you have claimed Overseas Workday Relief under the previous regime or had mixed-source income, careful apportionment and correct declaration are critical. For example: someone who worked remotely from another country for part of the year may only be eligible for relief for days spent abroad, and must calculate accordingly.
## Planning Strategies & Caution Points
* **Asset Re-basing**: For pre-2019 assets, you may have election options to re-base to lower values—reducing future capital gains tax. Explore if this applies to you.
* **Using TRF**: Determine if you can take advantage of reduced tax on pre-April 2025 foreign income/gains. Be mindful that some trust-based income doesn’t qualify.
* **Trusts & Inheritance Tax**: IHT rules move toward being residence-based; trusts with non-UK settlors may be affected. Seek earlier determinations. ([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))
## Compliance Steps for Globally Mobile Individuals
1. **Review tax residence status** per UK statutory residence test. Your past 10 years outside the UK matter.
2. **Gather foreign income and gains records** from 2019 to date—especially for overseas property, investments or trusts.
3. **Consult on re-basing elections** before deadlines.
4. **Plan your arrival or exit timing** carefully—some benefits apply only if you become UK resident after a long non-UK residency period.
5. **Payroll & employer reporting** should reflect new FIG regime—ensure correct coding and PAYE application. Employers and agents should keep updated.
## Example Scenarios
| Scenario | Before 6 Apr 2025 | After Enacting New Rules |
|----------|----------------------|---------------------------|
| Alice moves from US to UK in 2025 after 11 years non-residency. Owns foreign portfolio gains not remitted previously. | She might’ve used the remittance basis, with liability only on remitted income. | Under FIG, Alice pays no tax on her foreign income/gains for first 4 years, but needs to report UK source income. She can use TRF to repatriate past income at a reduced rate. |
| Bob has foreign trust distributions from non-UK settlors. | Could have preferential treatment under old domicile rules. | Post-6 Apr 2025 trusts from non-UK settlors may be taxed under residence-based IHT rules and lose certain reliefs. |
## Action Checklist for Non-UK Domiciled & Globally Mobile Individuals
* Confirm your date of UK tax residency and prior residency history.
* Calculate whether you meet the FIG eligibility criteria (10 years non-UK residence).
* Collect all foreign income/gain records especially from pre-2019 for re-basing options.
* Seek advice on trust structure, employer PAYE obligations, and inheritance tax with changes in residence-based rules.
* Keep abreast of guidance from HMRC on how rules are being interpreted in practice—it’s still an evolving area.
These changes aim to equalize tax treatment, reduce complexity, and encourage fairness. While transitions can be technical and dense, active preparation can protect your finances and improve compliance.