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Digital Nomad

UK Non-Dom and Foreign Income Regime: Digital Nomads and Long-Term Movers

With the remittance basis abolished and the new Foreign Income & Gains (FIG) regime in place since April 2025, digital nomads and long-term movers need new strategies for tax planning and residency decisions.

By NomadicTax Research Team · 5-8 min read

What Changed for Non-UK Domiciled Individuals

From 6 April 2025, the UK formally abolished the remittance basis for non-domiciled (non-dom) individuals. In its place, the Foreign Income & Gains (FIG) regime applies to those becoming UK tax residents who have previously resided outside the UK for 10 tax years. (gov.uk)

Key features:

  • A four-year exemption for FIG for qualifying individuals—no UK tax on foreign income or gains during that period, nor on non-resident trust distributions. (gov.uk)
  • If not eligible for FIG, remittance basis users transition via reduced rates (e.g. 50% tax on foreign income) for the 2025-26 tax year only. After that, all worldwide income and gains are taxed on the arising basis. (gov.uk)

Implications for Digital Nomads and Movers

Digital nomads, long-term remote workers, or individuals who are mobile internationally should consider the following planning points:

Tax Residence Timing

  • Planning arrival dates matters—eligibility for FIG depends on prior non-UK residence for 10 years. Arriving before or after an accounting year change may affect the 4-year exemption period.

Repatriation Decisions

  • Foreign income & gains generated before the residency date may still be exempt under FIG. Bringing them to the UK during exemption period can be tax-neutral if they fall under FIG.
  • Post-FIG or non-eligible individuals will be liable on worldwide income as soon as they become UK tax resident after their FIG window ends.

Trust and Inheritance Tax Changes

  • Non-dom individuals will no longer benefit from remittance basis in trust distributions.
  • Inheritance Tax moving from domicile basis toward residence basis—assets outside UK may be more exposed. (gov.uk)

Practical Tax Planning Strategies

  • Consider staying non-resident for longer if eligibility for FIG is within reach.
  • Sequence income and gains before arrival where legally possible, taking advantage of FIG’s exemption period.
  • Review overseas trusts or structures, especially distributions—pre-resident trusts and those operating post-April 2025 differ in treatment.
  • Document the source and timing of income/gains to support eligibility under FIG.
  • Seek advice early because transition is complex—missteps can lead to significant unexpected liability.

Case Study

<ins>Case: “Nomad Nina”</ins>

  • Has lived abroad for 15 years; plans to become UK tax resident in 2026.
  • Under new system, Nina will qualify for FIG: for 4 tax years after arrival she won’t pay UK tax on foreign income & gains, nor need to worry about trust distributions abroad.
  • Any income from UK sources or gains realised in UK during that time will still be taxable.
  • After four years, all global income/gains will be taxed in UK—so Nina could plan big capital realisations or trust movements either during or before FIG period.

Risks and Traps

  • Losing eligibility by not meeting the 10-year prior-residence rule.
  • Unregistered trusts or undisclosed foreign gains can cause surprises—especially post FIG exemption.
  • Residence status complexities—Statutory Residence Test still applies and has detailed day count and tie rules.

Conclusion

For digital nomads and long-term movers, the transition from remittance basis to FIG is a game-changer. Those who plan residency timing, income sourcing, and foreign structures carefully will gain benefit. The key is acting ahead—well before the four-year exemption window ends.

Sources

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