Digital Nomad
Planning for UK Non-Domicile Tax Changes: What Digital Nomads Should Know
How the UK’s new residence-based system for non-domiciled individuals replaces the remittance basis and what digital nomads, expats and globally mobile professionals need to plan now.
By NomadicTax Research Team • 5-8 min read • November 22, 2025
## Overview of the New Regime from April 6, 2025
From 6 April 2025, the UK abolished the traditional **non-domicile (non-dom)** status and remittance basis system. It introduced a **residence-based regime** that applies to non-UK domiciled individuals, replacing domicile as the key factor and focusing on tax residence instead. ([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))
Key features for those coming to live or continuing to live in the UK:
- The new **4-year Foreign Income and Gains (FIG)** regime: eligible non-UK domiciled individuals, after a 10-year period of non-UK residence, get **100% relief on foreign income and gains** for their first 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))
- Simplified **Overseas Workday Relief (OWR)** remains for the first 3 tax years of UK residence for those opting into FIG. ([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))
- Foreign income/gains from non-resident trust structures are taxed on an arising basis for those who do *not* qualify for the FIG regime. ([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))
- Transitional and grandfathering rules including a **Temporary Repatriation Facility (TRF)** allowing remittances of pre-6 April 2025 FIG income/gains to be taxed at a reduced rate of 12% in tax years 2025-26 and 2026-27 for eligible individuals. ([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))
## Implications for Digital Nomads and Globally Mobile Individuals
If you are a digital nomad, expat, or work across borders, these changes are material:
- A nomad who was non-resident in the UK for 10 consecutive years, then moves to the UK, can make use of the 4-year FIG regime. That means **foreign earnings and capital gains** outside the UK can be brought in without extra UK tax (assuming FIG conditions are met).
- Any trust income or gains arising *after* 6 April 2025 from non-resident trust structures for non-qualified individuals will be taxed as they arise, which removes previous protections.
- For those who had already accumulated foreign income/gains under the old remittance basis, TRF gives a **limited-period relief** at 12%. But note: does *not* cover trust-based foreign amounts accumulated under many structures.
## Actionable Planning Steps
1. **Review your status and past residence**: If you’ve been non-UK resident for the prior 10 years, chances are figure-in eligibility for the 4-year relief. If not, the default arising rules will apply.
2. **Consider timing of arrivals and remittances**: Bringing foreign income/gains into the UK during FIG years may be tax-free, but after those four years, they’ll be taxable on the arising basis. Delaying arrival could affect your treatment and reliefs.
3. **Evaluate whether to opt into FIG earlier**: Early applicants may benefit significantly from FIG and OWR provisions.
4. **Trust arrangements evaluation**: If you’re a settlor or beneficiary of overseas trust(s), especially non-resident ones, assess the tax consequences under the new regime. Pre-6 April gains may still be impacted under matched remittances or distributions.
5. **Use the TRF if available**: For eligible persons the TRF provides a chance to repatriate income/gains at 12% tax for two years only; missing that window may mean full taxation later.
## Practical Examples
| Scenario | Outcome Under New Regime |
|---|---|
| Sarah lived outside UK for 15 years, moves to UK in 2025. She has foreign investments with gains. | She can use the FIG regime: for first 4 years UK resident she pays no UK tax on foreign income/gains (assuming FIG eligibility). Trust distributions will be taxed if trust is non-resident. |
| Tom has been UK resident while claiming remittance basis, holding assets with gains from 2018. | He can use TRF to remit these pre-6 April 2025 amounts at **12% tax** in 2025-26 and 2026-27. Excludes trust-based gains under certain structures. |
| An influencer live streaming globally, earning abroad and selling content from UK base. | Under FIG or if not qualifying, worldwide income/gains taxed on arising; need to track residence, timing, and possibly adjust structure (e.g. overseas company) but beware anti-avoidance rules. |
## Risks & Caveats
- Failing to meet conditions for FIG (e.g. not meeting the 10-year non-UK residence rule) means you get no relief.
- Trust structures may trigger serious tax on distributions or gains.
- Post-FIG years see foreign income/gains taxed as they arise, so plan to use FIG years optimally.
- TRF is temporary. Missing its limited period means losing favourable rate.
## Summary
The UK’s new tax regime marks a **fundamental shift** from domicile-based non-dom rules to a **residence-based system** that emphasizes foreign income and gains as they arise, with a window of relief for certain individuals. Digital nomads, freelancers earning internationally, and trust-linked individuals must evaluate their residence history, structural arrangements, and timing of income carefully to optimise their position under the new rules. The changes bring greater predictability but also reduced opportunity for indefinite sheltering. Planning now is essential to make the most of transition and reliefs.