Executive Summary: The UK has overhauled its "non-dom" tax system, replacing it with the Foreign Income and Gains (FIG) regime. For qualifying new residents, this means 100% tax relief on foreign income and gains for the first four years of residency, with no remittance charge. This guide explores how to maximize these four tax-free years.
The End of Non-Dom Status
On 6 April 2025, the United Kingdom officially abolished the centuries-old "non-domiciled" status and the remittance basis of taxation. This seismic shift in policy was designed to modernize the UK's tax system, making it more transparent and based on residence rather than the complex concept of domicile.
FIG Regime Snapshot (2025/2026)
The Foreign Income and Gains (FIG) regime is the direct successor to the remittance basis, offering a simplified but time-limited window of tax efficiency for high-net-worth individuals relocating to the UK.
- Duration: First 4 consecutive tax years of UK residence.
- Exemption: 100% relief on foreign income and gains.
- Remittance: Funds can be brought into the UK with zero tax (unlike the old rules).
- Requirement: Must have been non-resident for 10 years prior.
Who Qualifies for the 4-Year Exemption?
To access the FIG regime, an individual must be a UK tax resident under the Statutory Residence Test (SRT) and have been a non-UK tax resident for at least 10 consecutive tax years immediately prior to their arrival.
| Feature | Old Remittance Basis | New FIG Regime (2026) |
|---|---|---|
| Duration | Up to 15 years | Max 4 years |
| Remittance Charge | £30k - £60k after 7-12 years | £0 (No charge) |
| Bringing funds to UK | Taxable as income/gains | Tax-Free |
| Reporting | Complex "mixed fund" tracking | Simplified reporting via Self-Assessment |
Strategic Implementation
- Timing your arrival: If you arrive mid-tax year, that year counts as your "Year 1". Consider arriving on April 6th to maximize the 48-month window.
- The 10-Year Test: Ensure you have no "UK ties" that could inadvertently trigger residency earlier than expected.
- Self-Assessment: You must proactively claim FIG relief on each annual tax return; it is NOT automatic.
The Temporary Repatriation Facility (TRF)
For former non-doms who still have untaxed foreign income and gains from before April 2025, the TRF provides a lucrative exit route. This mechanism allows you to bring those "legacy" funds into the UK at a significantly reduced tax rate (12% in 2025/26 and 15% in 2027/28) compared to the standard 45% income tax rate.
Technical Note on IHT
Inheritance Tax (IHT) has also shifted to a residence-based model. Under the 2026 rules, your worldwide estate becomes subject to UK IHT once you have been resident for 10 out of the last 20 years. This creates a "tail" provision where you remain in the UK IHT net for several years even after leaving.
Conclusion
While the new FIG regime is shorter than the old remittance basis, its simplicity and the ability to bring funds into the UK tax-free make it a powerful tool for global mobility. For HNW individuals, the first 48 months in the UK now offer a unique "tax holiday" to structure assets before the worldwide taxation net closes in.