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 • April 11, 2026
## 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](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))
- 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](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))
- 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](https://www.gov.uk/government/publications/2024-non-uk-domiciled-individuals-policy-summary/changes-to-the-taxation-of-non-uk-domiciled-individuals?os=wtmbtqtajk9s&utm_source=openai))
- 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](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 & Frequent Movers
| Situation | What counts as “resident” | How FIG relief might apply |
|---|---|---|
| Arriving in the UK after 10 years abroad | Resident from the tax year they arrive; can opt into FIG regime for first 4 years | Foreign income/gains for those four years are not taxed, even if remitted, but may lose personal allowances ([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))|
| Already residing in UK before reform | FIG availability depends; many former remittance-based users may be ineligible or face transitional rules | May need to declare worldwide income and gains normally, unless TRF applies for pre-6 April 2025 amounts ([gov.uk](https://www.gov.uk/government/publications/2024-non-uk-domiciled-individuals-policy-summary/changes-to-the-taxation-of-non-uk-domiciled-individuals?os=wtmbtqtajk9s&utm_source=openai))|
## 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](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))
- **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](https://www.gov.uk/government/publications/2024-non-uk-domiciled-individuals-policy-summary/changes-to-the-taxation-of-non-uk-domiciled-individuals?os=wtmbtqtajk9s&utm_source=openai))
## 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](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))
**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.