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Digital Nomad

Tax Planning for Global Nomads: Managing the UK’s New Residence-Based Regime

How the UK’s shift from domicile to residence-based taxation for foreign income affects nomadic individuals, and strategies to reduce exposure under the new FIG regime.

By NomadicTax Research Team · 5-8 min read

Overview of the UK’s Non-Domicile Reform

From 6 April 2025, the UK abolished the concept of non-domiciled status, replacing it with a residence-based system. Under the new framework:

  • New arrivals (having been non-resident for at least 10 years) can claim a 4-year Foreign Income and Gains (FIG) relief: foreign income or gains arising outside the UK are not taxed even if brought into the UK. (gov.uk)
  • All individuals who do not qualify under the FIG relief are taxed on their worldwide income and gains. The remittance basis is no longer available. (gov.uk)
  • Inheritance Tax (IHT) now operates on a residence-basis rather than domicile. Individuals in scope must be UK resident for 10 years prior to the chargeable event (death or gift), or include a 10-year period after leaving the UK. (gov.uk)
  • A Temporary Repatriation Facility (TRF) allows pre-6 April 2025 foreign income/gains to be brought into the UK at a reduced tax rate for a limited period. (gov.uk)

Implications for Digital Nomads & Frequent Movers

SituationWhat counts as “resident”How FIG relief might apply
Arriving in the UK after 10 years abroadResident from the tax year they arrive; can opt into FIG regime for first 4 yearsForeign income/gains for those four years are not taxed, even if remitted, but may lose personal allowances (gov.uk)
Already residing in UK before reformFIG availability depends; many former remittance-based users may be ineligible or face transitional rulesMay need to declare worldwide income and gains normally, unless TRF applies for pre-6 April 2025 amounts (gov.uk)

Strategies to Manage Tax Exposure

  • Track days of residency: Since residence determines eligibility, keeping detailed travel/residence logs is critical to determine whether one qualifies for FIG.
  • Use TRF where eligible: For pre-April 2025 foreign income, using TRF may allow favorable rates or exemptions; plan timing of remittances accordingly.
  • Consider structuring trusts wisely: New rules remove protections for certain trusts, especially ‘‘excluded property trusts’’. If you hold assets via trust structures, review their treatment under the regime. (gov.uk)
  • Rebase foreign assets: Under new CGT rules, former remittance-based users may rebalance the base value of foreign assets at a new date to reduce future capital gains liability. (gov.uk)

Example Scenarios

  1. Nomad arriving after long absence: Jane moves to UK in September 2025, having lived abroad since 2015. She qualifies for the FIG regime for tax years 2025-26 through 2028-29. Any overseas savings or gains earned during that time, even if she transfers them to the UK bank account, are exempt. But she must declare UK income normally.

  2. Existing resident losing remittance basis: Tom has lived in UK and claimed remittance basis before April 2025. His foreign rental income for 2024-25 might be brought into UK now; TRF may allow him to remit pre-April 2025 FIG at reduced rate. Future new foreign gains will be taxed as arising basis.

Actionable Advice

  • Consult a specialist tax adviser to map your residence history and check FIG eligibility.
  • Delay remittances of foreign income until you’ve evaluated whether TRF or reliefs apply.
  • Review trust and estate planning documents to ensure compliance under new IHT rules.
  • Stay informed on HMRC guidance – UK government plans further consultations especially around overseas anti-avoidance and transfer of assets abroad legislation. (gov.uk)

Bottom line: The change to a residence-based regime in the UK demands proactive planning if you move frequently, hold offshore income, or have cross-border family or trust assets. The right strategy can preserve tax advantages; the wrong one exposes you to full taxation.

Sources

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