Tax Planning
Tax Planning Opportunities After the UK’s Domicile Regime Overhaul
With the removal of the remittance basis and introduction of the Foreign Income & Gains regime from 6 April 2025, new planning windows have opened—and closed—for non-UK domiciled individuals. Understand what you should do now.
By NomadicTax Research Team • 5-8 min read • March 14, 2026
## Introduction
From 6 April 2025, the UK abolished the **remittance basis** of taxation and replaced its system for non-UK domiciled individuals with a **residence-based regime**. Individuals newly UK resident who were non-resident for at least ten years can now opt into a **Foreign Income & Gains regime** that provides relief on foreign income and gains for their first four years in the UK. ([gov.uk](https://www.gov.uk/government/publications/tax-changes-for-non-uk-domiciled-individuals/reforming-the-taxation-of-non-uk-domiciled-individuals?utm_source=openai))
This change brings significant implications for tax planning, especially for those who have investments or income abroad or trust interests. Here’s how to make the most of the transition.
## Key Elements of the New Regime
- **Eligibility**: Must be newly UK resident and non-resident for the preceding 10 years. ([gov.uk](https://www.gov.uk/government/publications/tax-changes-for-non-uk-domiciled-individuals/reforming-the-taxation-of-non-uk-domiciled-individuals?utm_source=openai))
- **Four-year relief period**: Foreign income & gains arising during the first four years of residence can be relieved from UK tax. ([gov.uk](https://www.gov.uk/government/publications/tax-changes-for-non-uk-domiciled-individuals/reforming-the-taxation-of-non-uk-domiciled-individuals?utm_source=openai))
- **Overseas Workday Relief (OWR)**: Continues to apply; allows relief for foreign employment income for work done abroad while UK resident under the new regime. ([gov.uk](https://www.gov.uk/government/publications/globally-mobile-employees?utm_source=openai))
## Immediate Actionable Steps
1. **Assess your residency timeline** – confirm when you became UK resident and how long you were non-resident prior. Qualifying for relief depends on this. If you're approaching this date, consider timing your arrival accordingly.
2. **Rebase assets ahead of arrivals** – where possible, make use of the option to rebase asset value to 5 April 2019 to mitigate future capital gains tax exposure. ([assets.publishing.service.gov.uk](https://assets.publishing.service.gov.uk/media/6929b353345e31ab14ecf735/E03444720_Budget_2025_Web_Accessible.pdf?utm_source=openai))
3. **Bring ahead income or gains** – if timing permits, consider realizing foreign gains or income before your arrival in UK, or during non-resident years, to avoid being caught under the new arising basis.
4. **Review trust structures** – existing trusts that benefited under remittance or domicile-based rules will be affected. Examine whether any changes in trustee residency or situs could impact future liabilities. ([assets.publishing.service.gov.uk](https://assets.publishing.service.gov.uk/media/6929b353345e31ab14ecf735/E03444720_Budget_2025_Web_Accessible.pdf?utm_source=openai))
## Examples
- *Case A*: A high net worth individual who lived abroad for 12 years becomes UK resident in 2025. Under the new regime, their foreign dividends and gains accrued after arrival are relieved for four years, offering time to adjust investment structures.
- *Case B*: Someone with foreign employment income performing overseas duties qualifies for OWR under the new regime. They can claim relief on those foreign earnings if they meet the requirements.
## Risks & Things to Avoid
- Failing to qualify due to subtle residency rules – structured travel, split-year, and work abroad all affect eligibility.
- Delaying action until after arrival – losses in reliefs may be irrecoverable.
- Using offshore trusts in ways that draw HMRC attention – transparency rules are tougher.
## Conclusion
The UK reform of the domicile regime significantly changes tax obligations for non-UK domiciled individuals. Those who act swiftly—validating eligibility, rebasing assets, aligning income timing, and reviewing trusts—can achieve substantial tax relief in the first four years of UK residence while avoiding costly missteps.