Tax Planning
Tax Planning Strategies under the New Foreign Income and Gains Regime
With the UK replacing domicile with a residence-based regime from April 2025, non-UK domiciled individuals face dramatic shifts. Here’s how to plan given the FIG regime, Temporary Repatriation Facility, and inheritance tax changes.
By NomadicTax Research Team • 5-8 min read • August 9, 2026
## Understanding the Regime Shift
From **6 April 2025**, the UK abolished the concept of **domicile** for tax purposes and implemented a residence-based tax system.([assets.publishing.service.gov.uk](https://assets.publishing.service.gov.uk/media/672105124da1c0d41942a8a8/Reforming_the_taxation_of_non-UK_individuals.pdf?utm_source=openai)) Under this new framework:
- A **4-year foreign income and gains (FIG)** relief applies for new arrivals who haven’t been UK tax resident in any of the previous 10 years; for those 4 years, qualifying foreign income and gains may get **100% relief**.([assets.publishing.service.gov.uk](https://assets.publishing.service.gov.uk/media/672105124da1c0d41942a8a8/Reforming_the_taxation_of_non-UK_individuals.pdf?utm_source=openai))
- The **remittance basis**, which allowed non-doms to pay UK tax only on foreign income brought into the UK, has been removed.([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=io.&utm_source=openai))
- Inheritance Tax (IHT) liability for non-UK assets will now depend on residence rather than domicile, with individuals needing to have been UK resident for 10 years prior to the chargeable event.([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=io.&utm_source=openai))
- A **Temporary Repatriation Facility (TRF)** provides a transitional route: those who used the remittance basis may remit pre-6 April 2025 foreign income and gains under the TRF and pay a reduced rate over a limited period.([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=io.&utm_source=openai))
## Key Planning Steps & Practical Examples
**1. Timing Entry into UK Residence**
If you are considering becoming UK tax resident, plan your arrival well: once resident for UK, the 10-year lookback for residency for IHT purposes starts immediately. For FIG relief access, prior UK non-residence for 10 years is required.
**Example:** If you were last UK resident 11 years ago, arriving now gives you eligibility for the 4-year FIG relief immediately. If last UK residence was 8 years ago, you won’t qualify until you’ve been non-resident for 10 full years.
**2. Pre-April 2025 Foreign Assets Planning**
The TRF applies to FIG arising before 6 April 2025: those assets may be remitted under favourable terms. Consider structuring distributions or income extraction to make use of this window.
**3. IHT Exposure Management**
Given IHT moves to a residence-based test, those who were previously shielded via domicile may now face IHT on non-UK assets. Consider trusts and trusts’ reporting, and possibly rebase assets where available.
**4. Where Employment or Income is Overseas**
Overseas Workday Relief (OWR) still exists; employees who physically work abroad may retain reliefs under certain conditions. Ensuring days abroad are properly documented will be fundamental.
## Actionable Advice for Digital Nomads & Non-UK Dom Individuals
- **Track your total days in the UK** and your previous UK residency years to determine IHT and FIG eligibility.
- For any foreign trusts or structures, review whether they still qualify under the new rules, particularly if settlor-interested or otherwise connected to non-UK income/gains.
- Plan any inheritance or estate transfers early; once resident for 10 years any non-UK assets may be within IHT.
- Maintain tight documentation of foreign income, gains, remittances and overseas working days.
- Review your software and tax advice arrangements to account for changing filing obligations, especially around FIG disclosures.
## Wrap‐Up
The FIG regime and residence-based IHT overhaul represent one of the most significant tax shifts in recent UK history. Non-UK domiciled individuals, digital nomads and estate planners should engage early, get professional advice, and build timelines to maximise reliefs and limit liabilities under the new system. Adjust your plans now—this is a regime that’s already in force.