Tax Planning
Planning for Non-Doms in the New UK Foreign Income & Gains Regime
With the non-dom status ending April 2025, high-net-worth individuals must adapt fast. This article unpacks the new Foreign Income & Gains regime and shows how to plan effectively with examples.
By NomadicTax Research Team • 5-8 min read • February 23, 2026
## What’s Changing – From Remittance Basis to Residence-Based Taxation
- From **6 April 2025**, the UK is abolishing the remittance-basis for non-UK domiciled individuals and replacing it with a **Residence-Based Foreign Income & Gains (FIG) regime**.{{citeturn0search0turn0search5turn0search11}}
- Under FIG, new arrivals who **haven’t been UK tax-resident for any of the previous 10 tax years** can receive **100% relief** on foreign income and gains **for their first four years** of UK residence.{{citeturn0search0turn0search5}}
- There’s also a **Temporary Repatriation Facility (TRF)** to allow remittance of pre-6 April 2025 foreign income and gains at reduced rates over a limited period.{{citeturn0search0turn0search11}}
## Key Implications for Financial & Estate Planning
- **Tax liability shifts**: If you’ve been using the remittance basis, you may have minimized UK tax by keeping income overseas. Under FIG, overseas income/gains may be taxed as they arise—even if not remitted.{{citeturn0search11turn0search5}}
- **Loss of certain allowances**: For those electing into FIG, **personal allowance** and the CGT annual exempt amount may be lost or reduced; always check the specific rules.{{citeturn0search11}}
- **Inheritance Tax (IHT) reform**: The UK is switching IHT from a domicile test to a **residence-based test** from 6 April 2025. Worldwide assets may become taxable for individuals resident in the UK for sufficient years.{{citeturn0search0turn0search5}}
## Examples & Scenarios
| Scenario | Old Rule | New FIG Rule (after April 2025) |
|---|---|---|
| **A wealthy non-dom arriving in UK in 2026, not UK-resident prior 10 years** | Could use remittance basis to avoid tax on foreign income unless remitted | Eligible for full relief on foreign income/gains under FIG for first 4 years; outside FIG, taxed on worldwide income/gains; pre-April-2025 liabilities still matter under TRF |
| **Non-dom who lived in UK for many years** | Deemed domicile may have triggered UK taxation of worldwide assets already | Under FIG, not much changed—resident status dominates; IHT worldwide assets may be in scope if long-term UK resident |
## Actionable Steps Before & After the Transition
1. **Audit your foreign income and gains now**: record amounts, assets, trusts, so you can use TRF optimally.
2. **Plan arrival timing**: if you haven’t been UK tax resident in the past 10 years, your arrival date determines eligibility.
3. **Review trust structures**: settlor or beneficiary traits matter; protections being removed or narrowed.
4. **Estate planning**: consider residence-based IHT rules; adjust wills, ensure trusts align with new regime and test whether reliefs still apply.
## Conclusion
The non-dom regime is gone. The FIG regime replaces it with **residence-based tax principles** that simplify some areas but increase exposure in others. Anyone with foreign income, trusts, or complex international arrangements should act now—make use of TRF, assess your status, adjust planning—and avoid surprises from the reforms.