Digital Nomad
Thriving Under The New Non-Dom Tax Regime: What Expats Need To Know
The UK has shifted from a domicile-based to a residence-based tax system as of 6 April 2025—this article helps expats and returning UK residents understand the new Non-UK Income & Gains (FIG) regime, Overseas Workday Relief, and Temporary Repatriation Facility.
By NomadicTax Research Team • 5-8 min read • April 16, 2026
## What’s Changed for Non-UK Domiciled Individuals
As of **6 April 2025**, the UK ended the traditional remittance-basis regime for non-UK domiciled tax treatment. It replaced domicile status with a system based on **UK tax residence**. Key components include:
- A **4-year Foreign Income & Gains (FIG)** regime for individuals who become UK tax resident after at least 10 years outside the UK. During these first four years, FIG arising while abroad is not taxed when brought into the UK. ([lordslibrary.parliament.uk](https://lordslibrary.parliament.uk/economic-and-taxation-policy-impact-on-growth-jobs-and-prosperity/?utm_source=openai))
- Abolition of protection for future income and gains in non-resident trusts (unless you qualify under the new FIG regime) ‒ new trust-based income is taxed on an arising basis. ([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))
- Retained but modified **Overseas Workday Relief (OWR)**: simplified criteria, eligibility extended from three to four tax years, and an annual cap on the financial amount claimed. ([assets.publishing.service.gov.uk](https://assets.publishing.service.gov.uk/media/672105124da1c0d41942a8a8/Reforming_the_taxation_of_non-UK_individuals.pdf?utm_source=openai))
- A new **Temporary Repatriation Facility (TRF)** for pre-6 April 2025 FIG: those who used remittance basis can elect to bring certain funds to the UK at a lower tax rate (approx. 12%) during a limited transition period (tax years 2025-26 and 2026-27). ([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) also moving from a domicile-based to a residence-based charge, subject to consultation, and will apply from **6 April 2025**. ([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))
## Practical Example
Imagine **Anna**, who has lived abroad for 15 years, returns to the UK on 6 April 2025 and qualifies under the new FIG regime:
- For the first four UK tax-years (2025-26 to 2028-29), income and gains earned overseas before returning won't be taxed when she brings them in.
- Any overseas trust income arising after 6 April 2025 would be taxed on arising basis unless wrapped into FIG eligibility.
- If Anna relocates work here, OWR relief may help for those four years, provided she meets residence and employment criteria.
- Assets she owns overseas also face different treatment under IHT if she is resident.
## Actionable Insights for Digital Nomads and Expats
- Determine your **UK tax residence date**—this triggers much of the new regime.
- Elect for **FIG regime** if eligible, to take advantage of the 4-year period.
- Browse options for trust structures carefully—trust distributions and arising gains are now more exposed.
- If using OWR relief, track days spent abroad and income thresholds; use software or an adviser to calculate.
- Prepare for IHT changes—review overseas assets and wills, and consider trusts or lifetime gifts earlier if needed.
## Why It Matters
These reforms represent one of the most significant shifts for international individuals in UK tax law in decades—removing long-standing domicile regimes, altering taxation of overseas income/gains and estate taxes. For global professionals, entrepreneurs, and expats, getting the new rules right can lead to substantial savings—or unexpected liabilities if ignored.
Need help? Consult a UK tax adviser who specialises in non-dom issues and digital nomad income.