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 • April 10, 2026

## 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](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)) 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](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)) - 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](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)) ## 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](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 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.