Digital Nomad
Tax Planning for Digital Nomads: Navigating the FIG Regime after Domicile Reforms
With the domicile-based system ending from 6 April 2025, the UK’s new FIG regime offers opportunities — and pitfalls — for those with ties to multiple countries.
By NomadicTax Research Team • 5-8 min read • September 4, 2026
## Overview of the New FIG Regime
- As of **6 April 2025**, the UK removed the concept of domicile for tax purposes. It introduced a **residence-based system** that includes the new **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))
- The UK also introduced a **Temporary Repatriation Facility (TRF)** allowing individuals previously taxed under the remittance basis to designate pre-6 April 2025 FIG amounts and pay a reduced tax rate over three years. ([assets.publishing.service.gov.uk](https://assets.publishing.service.gov.uk/media/672105124da1c0d41942a8a8/Reforming_the_taxation_of_non-UK_individuals.pdf?utm_source=openai))
## Pros & Challenges for Digital Nomads
**Pros:**
- FIG regime gives **clearer rules** for tax on foreign income and gains for UK residents regardless of where income arises.
- The TRF provides a transitional opportunity for individuals previously under the remittance basis system.
**Challenges:**
- International tax treaties still in force may interact with FIG in complex ways.
- Obligations to report FIG and pay tax on gains or income may catch some digital nomads unaware, especially if they have been used to relying on remittance basis or non-dom status.
## Practical Planning Tips
- **Establish your UK tax residence** each tax year: SRT (Statutory Residence Test) remains the tool to do this. Count your days, ties, and broken years carefully. For example, “exceptional circumstances” can allow you to disregard up to **60 days** in a year. ([gov.uk](https://www.gov.uk/hmrc-internal-manuals/residence-and-fig-regime-manual/rfig22220?utm_source=openai))
- **Use the TRF smartly**: if you hold unrealised gains or income accrued before April 2025, planning the timing and rate of bringing them into the UK under the TRF might save tax.
- **Keep offshore funds truly offshore** if tax-efficient; under FIG, bringing money in (remittance) triggers UK tax unless reliefs apply.
- **Monitor foreign property and trusts**: anti-avoidance rules, especially for long-term UK residents, may bring more assets into UK IHT scope. ([gov.uk](https://www.gov.uk/government/publications/inheritance-tax-anti-avoidance-measures-for-non-long-term-uk-residents-and-trusts/inheritance-tax-anti-avoidance?utm_source=openai))
## Example Scenario
- *Nomad: Chris* has been moving each year between UK and Europe. At tax year 2025-26 Chris is deemed UK resident under the SRT. He held US LLC income under remittance basis before April 2025. Using TRF, he designates pre-April 2025 income and gains, spreads tax liabilities over three years, avoiding full tax all at once.
## Key Takeaways
1. Even for nomads, **residence matters** far more than domicile from April 2025 onward.
2. The decisions you make now—especially about bringing in foreign gains or structuring trusts—have long-term implications.
3. Working with cross-border tax experts is vital to navigate FIG, TRF, IHT rules and ensure compliance while optimising tax.