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Tax Planning

Navigating the New Residence-Based Regime: What Non-UK Domiciled Individuals Need to Know

With the abolition of the remittance basis from 6 April 2025, non-UK domiciled individuals must adjust to a new residence-based tax regime—this article breaks down the rules and offers practical planning tips.

By NomadicTax Research Team · 5-8 min read

What’s Changed for Non-UK Domiciled Individuals

As of 6 April 2025, the UK has abolished the remittance basis of taxation and replaced it with a residence-based regime. Under this new system, individuals who become UK residents but were non-UK domiciled will:

  • No longer be able to claim the remittance basis. (gov.uk)
  • Have their foreign income and gains (FIG) taxed based on residence rather than remitted status. (gov.uk)
  • Be eligible for transitional arrangements, such as the Temporary Repatriation Facility (TRF), enabling bringing in accrued foreign income/gains at a reduced rate (12%) for a limited period. (gov.uk)

Key Elements and Timelines

ElementDetails
Grace period / TRFReduced tax on previously accrued FIG, taxed at 12%, under the facility. (gov.uk)
Rebase of foreign assetsEligible individuals can rebase foreign assets for certain CGT purposes to 5 April 2017 (or 2019 in some rules) when meeting specific conditions. (gov.uk)
Overseas Workday Relief (OWR)Retained and reformed, including extensions and simplifications. (gov.uk)
Inheritance Tax changesResidence nil-rate band limits and rules fixed, tying UK inheritance taxation more closely to residence. (gov.uk)
Effective date6 April 2025. (gov.uk)

Implications and Opportunities for Planning

1. Assess Residency and Domicile Status Now

  • If you expect to become UK resident by or after 6 April 2025, consider how long you retain non-UK domicile status and what foreign assets/gains you hold. Early planning can reduce surprise tax costs.
  • Where possible, time asset disposals or foreign income flows to align with transitional reliefs.

2. Use the Temporary Repatriation Facility Wisely

  • If eligible, bring in foreign income/gains under TRF at the special 12% rate rather than deferring or remitting later at higher rates.
  • Ensure compliance with TRF application deadlines and documentation requirements.

3. Rebase Assets Strategically

  • Consider whether rebasing your foreign assets (for CGT) to the relevant date (e.g., 5 April 2017) will reduce taxable gain on future disposals.

4. Evaluate Overseas Workday Relief (OWR)

  • For workers spending time abroad but employed by UK employers, the reformed OWR may offer tax savings—track days carefully and understand eligibility.

Risks & What to Watch Out For

  • Higher tax exposure: Without remittance basis, foreign income/gains may now be taxable on arising rather than remittance—ensure you have full records.
  • Anti-avoidance rules that may impact transfers, trusts or other arrangements. (gov.uk)
  • Timing matters: missing the TRF window or failing to meet conditions could mean losing favorable treatment.

Practical Example

Lucy, a non-dom who has lived outside the UK for many years, becomes UK resident on 6 April 2025. She has foreign investment income accrued over years and some assets with large unrealised gains.

  • She opts into the TRF to bring in accrued income at 12% instead of later paying full UK income tax.
  • She rebases her foreign shares to 5 April 2017 under the rules to limit CGT when she eventually disposes of them.
  • She checks if she qualifies for OWR if she splits her work time between the UK and abroad.

Checklist for Implementation

  • Confirm dates of UK residence, domicile status and previous non-resident status.
  • Identify all foreign income, gains, and assets before 6 April 2025.
  • Calculate benefit of rebasing vs a later disposal.
  • Keep detailed records of employment abroad / days worked overseas if using OWR.
  • Seek professional advice for complex arrangements (e.g. trusts, offshore structures).

Becoming familiar with the new regime now can help non-UK domiciled individuals avoid avoidable tax charges and optimise planning for foreign income and assets.

Sources

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