Answers · UK 2025/26
How does the new Foreign Income and Gains regime work after non-dom abolition in 2025?
The non-domicile (remittance basis) regime was abolished from 6 April 2025. In its place, a new 4-year Foreign Income and Gains (FIG) regime applies to individuals who have not been UK tax resident in any of the previous 10 tax years. During the FIG period, foreign income and gains are exempt from UK tax regardless of whether they are remitted to the UK.
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The abolition of the remittance basis and the introduction of the FIG regime represents the biggest change to the taxation of foreign individuals in the UK for decades. **The old system (pre-April 2025)** Under the non-dom remittance basis, individuals domiciled outside the UK could elect to pay UK tax only on UK-source income and on foreign income remitted (brought) to the UK. Long-term non-doms paid a Remittance Basis Charge of £30,000 or £60,000 per year. **The new FIG regime (from 6 April 2025)** The new regime is residence-based, not domicile-based: - Applies to anyone who has not been UK tax resident in **any of the previous 10 consecutive tax years** - For the first **4 years** of UK tax residence, foreign income and gains (FIG) are completely exempt from UK tax - No charge to access the relief (unlike the old RBC) - FIG can be **freely remitted** to the UK without triggering UK tax - After 4 years, worldwide income and gains are fully taxable in the normal way **Transitional provisions** For existing non-doms who had been using the remittance basis: - **Temporary Repatriation Facility (TRF)**: foreign income and gains accumulated before April 2025 can be remitted at a reduced rate -- 12% in 2025/26 and 2026/27, rising to 15% in 2027/28 - **Rebasing**: foreign assets held before April 2019 can be rebased to their April 2019 value for CGT purposes, reducing future gains **Who qualifies for FIG?** A new arrival who has lived outside the UK for 10+ years qualifies from day one of UK residence. Someone who was UK resident in any of the last 10 years does not qualify and is taxed on worldwide income immediately. **Domicile and IHT** Note that Inheritance Tax reform linked to these changes has introduced a new "long-term resident" concept (broadly 10 out of 20 years UK resident), replacing the previous domicile-based IHT scope. This is a separate but related change.
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This answer is informational only and does not constitute financial, tax or legal advice. Figures are for the 2025/26 UK tax year. See our methodology and sources.