Digital Nomad
Navigating the New UK Non-Dom Regime: What Digital Nomads Must Know
Significant reforms to the UK’s tax treatment of non-UK domiciled individuals (non-dom regime) took effect from 6 April 2025; digital nomads need to understand how the new residence-based rules, FIG regime, and Moving Abroad protections affect them.
By NomadicTax Research Team • 5-8 min read • April 11, 2026
## What’s Changed for Non-Domiciled Individuals
From **6 April 2025**, the **domicile-based tax residence regime** in the UK was replaced by a **residence-based system**. Rather than using the concept of domicile, the UK now taxes **all UK residents** on **foreign income and gains as they arise** (the ‘arising basis’), with limited reliefs for new residents under specific rules. ([gov.uk](https://www.gov.uk/government/publications/2024-non-uk-domiciled-individuals-policy-summary/changes-to-the-taxation-of-non-uk-domiciled-individuals?utm_source=openai))
Here are the key elements:
- **FIG Regime (“Foreign Income and Gains”)**: New residents who haven’t been UK tax resident in any of the ten years before arrival get 100% relief from foreign income and gains for their first **four years** of UK residence. After that period, all income and gains are taxed on the arising basis. ([gov.uk](https://www.gov.uk/government/publications/2024-non-uk-domiciled-individuals-policy-summary/changes-to-the-taxation-of-non-uk-domiciled-individuals?utm_source=openai))
- **Temporary Repatriation Facility (TRF)**: Individuals who used to enjoy the remittance basis (under the old rules) can still benefit. They can **remit pre-6 April 2025 foreign income and gains** and pay a **reduced UK tax rate** for a limited time period. ([assets.publishing.service.gov.uk](https://assets.publishing.service.gov.uk/media/672105124da1c0d41942a8a8/Reforming_the_taxation_of_non-UK_individuals.pdf?utm_source=openai))
- **Inheritance Tax (IHT) regime**: The UK replaced the overtime domicile-based IHT rules with a **residence-based test**. Now, foreign assets are brought into IHT if the individual has been UK resident for **10 years prior** to the tax year of death (or 10 years after leaving). The concept of domicile is being abolished in this context. ([gov.uk](https://www.gov.uk/government/publications/2024-non-uk-domiciled-individuals-policy-summary/changes-to-the-taxation-of-non-uk-domiciled-individuals?utm_source=openai))
- **Overseas Workday Relief (OWR)** has been reformed: employees working overseas can continue to claim relief, but rules changed — including extending the period from **three to four years**, and introducing an **annual limit**. ([assets.publishing.service.gov.uk](https://assets.publishing.service.gov.uk/media/672105124da1c0d41942a8a8/Reforming_the_taxation_of_non-UK_individuals.pdf?utm_source=openai))
## What This Means for Digital Nomads
If you move to the UK or claim UK residence while continuing income or gains abroad, here’s how this affects your tax planning:
| Situation | Before Change | After Change (from Apr 6, 2025) |
|---|---|---|
| You’ve not been UK resident for ≥10 years before coming in | Could use remittance basis indefinitely, subject to conditions | Eligible for FIG regime: 100% relief for first 4 years, then taxed on arising basis |
| Foreign income/gains already earned pre-6 April 2025 | Taxed only if remitted (brought to UK) under old rules | Remitted income/gains taxed when brought in; TRF offers limited reduced rate on certain amounts for a transitional time ([assets.publishing.service.gov.uk](https://assets.publishing.service.gov.uk/media/672105124da1c0d41942a8a8/Reforming_the_taxation_of_non-UK_individuals.pdf?utm_source=openai)) |
| Inheritance of non-UK property | May have been outside IHT under domicile rules | Subject to IHT if long-term UK resident (10 years) or if death within 10 years of leaving UK residence ([gov.uk](https://www.gov.uk/government/publications/2024-non-uk-domiciled-individuals-policy-summary/changes-to-the-taxation-of-non-uk-domiciled-individuals?utm_source=openai)) |
## Actionable Steps for Digital Nomads
- **Track your residency**: Count tax years from arrival carefully; the four-year FIG regime gets swamped if you’ve been resident before. Absence of earlier residence can help you qualify as a qualifying new resident.
- **Evaluate existing overseas assets and trusts**: Pre-6 April 2025 gains held in overseas trusts or foreign income—ensure you understand TRF eligibility and rebasing rules because your affordable tax liabilities might depend on details. ([assets.publishing.service.gov.uk](https://assets.publishing.service.gov.uk/media/672105124da1c0d41942a8a8/Reforming_the_taxation_of_non-UK_individuals.pdf?utm_source=openai))
- **Plan work abroad with OWR in mind**: If eligible, claiming Overseas Workday Relief remains possible, but diligence on where work is performed and costs is essential. Keep timesheets, travel logs, avoid exceeding the new annual cap. ([assets.publishing.service.gov.uk](https://assets.publishing.service.gov.uk/media/672105124da1c0d41942a8a8/Reforming_the_taxation_of_non-UK_individuals.pdf?utm_source=openai))
- **Handle inheritance exposure**: Families with foreign property should understand that someone who’s been UK resident for 10 years may bring foreign assets into IHT. Consider reengineering schedules or ownership before and after crossing UK residency thresholds. Seek advice.
- **Consider timing**: If possible, defer becoming UK resident (if foreign income or gains are high) until you’ve arranged holdings, trusts, etc., to mitigate exposure. Use the TRF window for previously remitted amounts. Also consider the FOUR-year window for FIG benefits.
## Examples
1. **Florence**, freelance developer, moves to UK in September 2024, hasn't been UK resident in the prior 10 years. From 6 April 2025 she is a qualifying new resident; FIG regime applies for 2025-26, 2026-27, 2027-28, 2028-29 — all foreign income and gains taxed only on arising basis. After that, all foreign income/gains are taxable.
2. **Raj**, used remittance basis beforehand, has pre-April 2025 foreign income he hasn’t remitted. Under TRF, he can remit some of those amounts at reduced rate in specified years after the regime change.
3. **Anna**, UK-resident for 8 years buying overseas property. On her death after 10 years, that overseas property is in UK IHT estate. Owning via foreign trust may expose settlements to new IHT / relevant property regimes.
## Key Takeaways
- The non-dom regime as you knew it is gone from 6 April 2025.
- FIG regime and TRF offer transitional and relief possibilities—**timing and eligibility are crucial**.
- Digital nomads need careful planning on residency, trusts, foreign gains, and assets long before arrival to avoid surprise liabilities.
- Get bespoke advice early — details matter, as do your individual facts.
With clear understanding of the changes, digital nomads can still use the new UK tax regime to plan effectively, but the flexibility of the old non-dom rules has been reduced significantly. Be proactive, informed, and document everything.