Tax Planning
Tax Planning for UK Residents: Navigating the New Non-Domicile Tax Regime from April 2025
With the abolishment of the non-domicile regime and its replacement by a residence-based system, UK residents and newcomers must rework offshore tax planning, inheritance considerations, and investment decisions ahead of the April 2025 changes.
By NomadicTax Research Team • 5-8 min read • November 23, 2025
## What’s Changing?
- The non-UK domicile tax regime (remittance basis) is **abolished** from **6 April 2025**. From that date, tax residency alone will determine tax liability in the UK. **New arrivals** will pay UK tax “as everyone else” after **four years** in the UK. ([gov.uk](https://www.gov.uk/government/news/chancellor-delivers-lower-taxes-more-investment-and-better-public-services-in-budget-for-long-term-growth?utm_source=openai))
- Transitional arrangements for those currently using remittance basis include options to **rebase capital assets to 5 April 2019**, a two-year temporary repatriation facility at 12% tax, and a **50% exemption** for foreign income in the first year of the new regime. ([gov.uk](https://www.gov.uk/government/publications/spring-budget-2024/spring-budget-2024-html?utm_source=openai))
## Implications for Your Tax Planning
| Area | What You Need to Know | Action Steps |
|---|---|---|
| **Foreign Income & Gains** | These will be taxed on UK basis rather than remittance basis. The first four years for new residents offers some transitional leeway. | Review foreign holdings, consider when to move or realise assets. Rebase where possible. Consider delaying income remittances to avoid unexpected liability. |
| **Inheritance Tax & Trusts** | Offshore trusts and IHT exemptions based on domicile will change. Estates may no longer use domicile to reduce IHT. Requires shifting focus to **residency rules**. | Reassess estate planning, wills, and trust structures before April 2025. Ensure long-term resident status aligns with your plans. |
| **Investments & Residency Timing** | Moving to or from the UK now carries new implications. You may trigger tax liability sooner than under the old rules. | Plan your move in relation to the April 2025 start date. If possible, accelerate or defer transactions to avoid overlap. |
## Practical Example
Alice, an individual non-UK domiciled living in France, plans to move to London in May 2025. Under old rules, she’d have years to benefit from remittance basis. Under the new regime:
1. She becomes UK resident April-year occupancy rule for 2025-26.
2. First four years will still avoid full liability? Actually “new arrivals pay the same tax as everyone else after four years,” so first four years have **special treatment** (rebasing, possible exemption/repatriation facility). Alice should consider **bringing in capital assets before start**, rebase, or delay valuable foreign income until after arrival. She should engage advisors now.
## Actionable Insights
- **Act before 6 April 2025**: adjust asset locations, estate plans, trust status.
- **Document residence carefully**: long-term UK residence plays new roles (e.g. for IHT) under Finance Act 2025. ([legislation.gov.uk](https://www.legislation.gov.uk/ukpga/2025/8/part/1/enacted?utm_source=openai))
- **Use transitional facilities**: the rebasing option, repatriation facility at reduced rate.
- **Engage specialist advice**: foreign tax credits, double tax treaties, and timing will matter.
Understanding and preparing for this major regime shift is crucial for individuals and families with cross-border ties.