Digital Nomad
Tax Planning for Digital Nomads under the UK Residence-Based Regime
How non-UK domiciled individuals and digital nomads can adjust tax strategies under the new residence-based regime replacing domicile rules from April 2025.
By NomadicTax Research Team • 5-8 min read • September 12, 2026
## Understanding the New Regime
From **6 April 2025**, the UK removed the concept of domicile for most tax purposes and replaced it with a **residence-based system**. Alongside that, the **Foreign Income and Gains (FIG) regime** was introduced to give new UK residents favourable tax treatment during their first four years of residence. ([assets.publishing.service.gov.uk](https://assets.publishing.service.gov.uk/media/672105124da1c0d41942a8a8/Reforming_the_taxation_of_non-UK_individuals.pdf?utm_source=openai))
Digital nomads—people living and working in multiple countries—need to track both **days in the UK** for the Statutory Residence Test (SRT) and their **ties to the UK**, which affect their residence status. The SRT has been updated, including guidance on split-year treatment and temporary non-residence rules (e.g. for distributions from closely controlled companies). ([gov.uk](https://www.gov.uk/hmrc-internal-manuals/residence-and-fig-regime-manual/updates?utm_source=openai))
## Key Strategies for Digital Nomads
- Plan your **residency timing**: Know when you will be UK resident under SRT, considering automatic overseas/UK tests and UK ties. If you establish residence later in the tax year, split-year treatment may apply, limiting your UK tax exposure during periods abroad. ([gov.uk](https://www.gov.uk/hmrc-internal-manuals/residence-and-fig-regime-manual/updates?utm_source=openai))
- Understand FIG eligibility: Individuals qualifying as new residents may benefit from foreign income and gains being exempt or taxed on residence basis for four years. This can be a powerful tool for structuring when and how income is remitted to the UK. ([assets.publishing.service.gov.uk](https://assets.publishing.service.gov.uk/media/672105124da1c0d41942a8a8/Reforming_the_taxation_of_non-UK_individuals.pdf?utm_source=openai))
- Manage **remittance and temporary non-residence rules**: If you were non-resident and now resident, distributions from closely controlled companies have new temporary non-residence distribution rules under Finance Act 2026. Ensuring proper timing and structuring of distributions can avoid unexpected UK tax. ([gov.uk](https://www.gov.uk/hmrc-internal-manuals/residence-and-fig-regime-manual/updates?utm_source=openai))
- Keep detailed travel and activity records: UK ties (accommodation, work days, family, etc.) count heavily. Exceptional circumstances (like illness) may allow days in the UK without counting against you. ([assets.publishing.service.gov.uk](https://assets.publishing.service.gov.uk/media/69c2ab7d55cc7fccb3e0dbe3/SA109-Notes-2026.pdf?utm_source=openai))
## Practical Example
**Scenario**: Alice, a software developer, worked abroad until June 2026, then moved to the UK permanently, with income from her foreign consulting business. Under FIG, she may benefit for her first four UK years of residence, so for foreign income not remitted or gains kept abroad, UK tax may not apply. However, after her arrival she should plan whether to remit income, how to structure foreign distributions, and whether her past overseas ties give her split-year relief for 2025-26. Preserving documentation for days abroad, maintain proofs of overseas work, and avoid involuntary UK ties (e.g. accommodation) if trying to limit UK exposure.
## Actionable Advice
- Use an **expert adviser familiar with UK non-dom rules**; mistakes in residence/self-assessment or remittance may trigger exposure to income tax, capital gains, and inheritance tax.
- If in FIG regime, plan **when to remit foreign income/gains** to UK; consider leaving assets outside until after 4 years, or remit with tax planning.
- Ensure accurate travel diaries, accommodation records, work logs and UK tie details.
- For those in US, or countries with LLCs/reverse hybrids, consider recent UK consultations on reverse-hybrids taxation, which could affect your effective rate. (See the consultation for UK-resident members of US LLCs) ([gov.uk](https://www.gov.uk/government/consultations/uk-residentindividualmembers-of-llcs-and-otherreversehybrids?utm_source=openai))