Digital Nomad

What UK’s New Residence-Based Regime Means for Expats and Non-Doms in 2025-26

As the UK prepares to abolish the non-dom tax framework in April 2025, a new residence-based system emerges—with key transitional rules, thresholds and what expats must plan for.

By NomadicTax Research Team • 5-8 min read • November 20, 2025

## Overview of the UK Non-Dom Abolition and New Regime In recent announcements, the UK government has confirmed that the **non-domicile (“non-dom”) regime** will be fully abolished and replaced by a **residence-based tax system** from **April 6, 2025**. Under this new regime, new arrivals will pay taxes similarly to UK residents after four years of residence. ([gov.uk](https://www.gov.uk/government/news/chancellor-delivers-lower-taxes-more-investment-and-better-public-services-in-budget-for-long-term-growth?utm_source=openai)) ## Main Features of the Transition and New Rules - **Residence-based status after 4 years**: After four years’ residence, new arrivals will lose some tax advantages and begin broadcasting tax rules akin to those for long-term UK residents. ([gov.uk](https://www.gov.uk/government/news/chancellor-delivers-lower-taxes-more-investment-and-better-public-services-in-budget-for-long-term-growth?utm_source=openai)) - **First-year foreign income relief**: A temporary 50% exemption for foreign income in the first year of residence. The remittance basis is being replaced. ([gov.uk](https://www.gov.uk/government/publications/spring-budget-2024/spring-budget-2024-html?utm_source=openai)) - **Transitional measures**: - Those claiming the remittance basis before the regime change may be eligible to **rebase capital assets** to 5 April 2019. ([gov.uk](https://www.gov.uk/government/publications/spring-budget-2024/spring-budget-2024-html?utm_source=openai)) - Various exemptions or thresholds apply depending on length of residence and asset/gain type. ## Implications for Expats, Digital Nomads, and Non-Resident Investors - If you’re planning to move to the UK or are currently non-dom, you should review your **timeline**: spending four years in residence will shift your tax status significantly. - If you hold foreign assets or investments, rebasing them to 5 April 2019 may help avoid retroactive gains when the regime changes. - For digital nomads who travel in and out, consider tracking days carefully to know when you cross the residence year stretch. ## Example Scenarios | Scenario | Before April 2025 | After April 2025 | Resulting Tax Benefit or Risk | |---|---|---|---| | Non-dom moving in 2024 to UK | Remittance basis applies; only foreign income / gains remitted are taxed | Year 1: 50% exemption for first-year foreign income; after 4 years, treated like resident | Opportunity to plan capital gains before change; timing matters. | | Have property abroad with gain since 2019 | May rebasing to 5 April 2019 allow gain only from that date | Once resident, full disclosure regime applies | Gains incurred before 2019 could be sheltered. | | Digital nomad coming in and out frequently | Could use remittance basis strategically | Under new rules, may lose remittance basis; presence counts towards 4-year countdown | Requires tighter planning with tax advisor. | ## Actionable Steps to Plan Ahead - Audit your **residency timeline**: keep passport stamps / travel logs to track presence in UK or abroad. - Review your **foreign income** now—if you carry gains on foreign assets, consider disposing (or restructuring) before April 2025 under old rules. - Seek to rebase assets: understand valuation as of 5 April 2019 so you’re ready to use that rebasing if you qualify. - Consult with tax advisors familiar with UK non-doms, double taxation treaties, and cross-border scenarios. These changes are pivotal—a pivot from remittance basis to a fully residence-based system. For expats, timing and asset structure will be key in the transition to mitigate unexpected exposures under the new rules.