Digital Nomad

Non-UK Individuals and the 4-Year Foreign Income & Gains Regime: Opportunities & Pitfalls

The dom status and remittance basis rules ended in April 2025. Explore the new 4-Year Foreign Income & Gains (FIG) regime, who qualifies, how to claim it, and what to watch out for.

By NomadicTax Research Team • 5-8 min read • April 13, 2026

## Background: What changed on 6 April 2025 The UK abolished the remittance basis of taxation for non-UK-domiciled individuals. In its place, the government introduced a regime based on **residence**, not domicile status. ([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 that, individuals arriving in the UK after at least **ten consecutive tax years of non-UK residence** may claim the **4-year Foreign Income & Gains (FIG)** regime. ([assets.publishing.service.gov.uk](https://assets.publishing.service.gov.uk/media/672105124da1c0d41942a8a8/Reforming_the_taxation_of_non-UK_individuals.pdf?utm_source=openai)) ## Who qualifies for the 4-year FIG regime? To be eligible, you must: - Become UK tax resident after **10 consecutive tax years of non-UK residence**, under Statutory Residence Test (SRT). ([assets.publishing.service.gov.uk](https://assets.publishing.service.gov.uk/media/672105124da1c0d41942a8a8/Reforming_the_taxation_of_non-UK_individuals.pdf?utm_source=openai)) - Be within your **first four UK resident tax years** under this new regime. ([assets.publishing.service.gov.uk](https://assets.publishing.service.gov.uk/media/672105124da1c0d41942a8a8/Reforming_the_taxation_of_non-UK_individuals.pdf?utm_source=openai)) - **Make a claim** in your Self-Assessment tax return by **31 January in the second tax year** after the relevant year. For example, for 2025-26, due by 31 January 2028. ([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 is covered under the FIG regime? Eligible individuals can: - Bring foreign income and gains into the UK without extra charges for **four UK tax years**. ([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)) - Be taxed on **UK income and gains** as usual. Foreign trust distributions and non-resident trust income are included only if they meet relevant conditions. ([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)) ## Examples **Scenario A:** Laura lived outside the UK for 11 years then moves back in 2025-26. She qualifies for FIG. For that tax year and the next three, she can receive her non-UK income & gains without penalty. **Scenario B:** Tomas has been UK resident for 12 years but lived outside the UK for 9 years before that. He does **not** meet the 10-year non-UK residence requirement, thus not FIG-eligible. ## Key pitfalls and things to watch - FIG regime ends after four years; after that, **full world-wide income & gains** are taxable. Plan gains and foreign income timing accordingly. ([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)) - Non-UK trust income/trust distributions are treated differently and may lose protection. Seek specialist advice. ([gov.uk](https://www.gov.uk/guidance/tax-agents-handbook/getting-started?utm_source=openai)) - FIG claims must be precise: you need to quantify foreign income/gains in return. Failure to claim correctly may result in losing benefit. ([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) is transitioning to a residence-based model but details pending. Estate planning must consider current rules and upcoming change. ([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)) ## Opportunities to consider - For those eligible, arranging foreign income or gains in early qualifying years could provide meaningful tax advantage. - Trusts and offshore structures should be reviewed to see if their treatment changes, with particular attention to distributions or settlors. Use of professional advice is crucial. - Non-UK income/gains already arising prior to 6 April 2025 might be eligible for smoother transition under FIG claims or temporary relief structures. ([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)) ## Action plan for digital nomads or expatriates 1. Determine if you have satisfied 10 years of non-UK residence before becoming UK tax resident. 2. Plan to become UK resident in a year that maximises your FIG eligibility. 3. Assess your foreign income/gains across prior periods and structure any asset disposal considering timing relative to the FIG period. 4. Engage tax professionals for trust/distribution issues and future IHT planning. --- This regime replaces a long-standing system and opens up new planning windows—but only if you're eligible and act early. Understanding the limits, deadlines, and administrative steps will make the difference between gaining relief and being caught off guard. **Category: Digital Nomad**