UK non-domicile tax advice

This guidance has been updated for 2026 to reflect ongoing changes affecting non-UK domiciled individuals and globally mobile clients.

At Price Bailey, our Personal Tax team has long-standing experience supporting internationally mobile individuals with their UK tax affairs.

Following major changes introduced from 6 April 2025, the UK has moved away from the traditional non-domicile regime to a residence-based system of taxation. This means your UK tax position is now primarily determined by your residency status, rather than your domicile.

If you are UK resident and need support understanding how your overseas income and gains are taxed under the new rules, or how best to structure your affairs, our team can provide clear, practical advice tailored to your circumstances.

UK non-dom tax changes from April 2025

Before 6 April 2025, UK-resident non-domiciled individuals could usually claim the remittance basis, meaning UK tax generally applied to UK income and gains, while foreign income and gains were only taxed if they were brought into the UK.

From 6 April 2025, that regime ended for new foreign income and gains, and the UK moved to a residence-based system instead. Qualifying new arrivals may now claim a four-year foreign income and gains (FIG) regime, but only if they have been a non-UK resident for the previous 10 consecutive tax years.

The key change is that domicile is no longer the main factor for income tax and capital gains tax from 6 April 2025. Instead, most UK residents are taxed on their worldwide income and gains as they arise, regardless of whether the funds are kept offshore or remitted to the UK. For those who qualify for the FIG regime, eligible foreign income and gains can be relieved from UK tax for up to four tax years and can be brought to the UK without an additional tax charge during that period.

These changes represent one of the most significant shifts in UK personal taxation in recent years and mean that both new arrivals and existing non-domiciled individuals should review their position carefully.

Aspect	Before 6 April 2025	After 6 April 2025
Basis of taxation	Domicile-based system	Residence-based system
Access to remittance basis	Available to UK-resident non-domiciled individuals	No longer available for new foreign income and gains
Tax on foreign income & gains	Only taxed if remitted to the UK	Generally taxed as they arise, regardless of remittance
Short-term relief for new arrivals	Not applicable	4-year FIG regime available (if non-UK resident for previous 10 years)
Bringing funds into the UK	Could trigger a UK tax charge	FIG regime allows qualifying funds to be brought in without additional tax during the 4-year period
Role of domicile	Central to determining tax treatment	No longer the primary factor for income tax and CGT

Domicile, residency and the FIG regime explained

From 6 April 2025, the UK has moved from a domicile-based system to a residence-based approach for taxing foreign income and gains. This represents a fundamental shift for internationally mobile individuals.

Domicile vs residency

Previously, an individual’s domicile status determined whether they could access the remittance basis
From 6 April 2025, UK tax residency is now the primary factor for income tax and capital gains tax
As a result, most UK residents are taxed on their worldwide income and gains as they arise, regardless of whether funds are brought into the UK

Statutory Residence Test (SRT)

The Statutory Residence Test continues to determine whether an individual is UK tax resident in a given tax year. Residency status is therefore key to accessing the new rules, including eligibility for the four-year FIG regime

Four-year FIG regime (foreign income and gains)

A new four-year FIG regime is available from 6 April 2025 for qualifying individuals. To qualify, you must:

Become a UK tax resident.
Have been a non-UK resident for the previous 10 consecutive tax years.

If eligible, the regime can be claimed for up to four tax years of UK residency and must be elected annually.

Overseas income and gains

During the FIG period:

Only UK income and gains are taxed.
Foreign income and gains are exempt from UK tax.
These funds can be brought into the UK without additional tax charges.

After the four-year period:

Individuals are taxed on their worldwide income and gains on an arising basis.
The flexibility previously offered by the remittance basis is no longer available.

Who this applies to

New arrivals to the UK who meet the 10-year non-residence condition.
Returning UK residents after a prolonged period abroad.
Existing non-domiciled individuals, who may need to reassess their position under the new regime.

Tax planning considerations for non-doms

The move to a residence-based system means tax planning for non-domiciled individuals should now focus more on timing, structuring and ongoing compliance. Key areas to consider include:

Overseas income and gains

Understanding when and how foreign income and gains are taxed is now critical. Planning may involve timing disposals, structuring investments efficiently and making the most of any available reliefs, such as the four-year FIG regime where eligible.

Inheritance Tax exposure

The shift towards a more residence-based Inheritance Tax (IHT) system can bring non-UK assets within the UK tax net over time. Early review of asset ownership and long-term residency plans is important to manage potential exposure.

Offshore trusts and structures

Existing trust and offshore arrangements may no longer provide the same level of protection from UK tax. These structures should be reviewed to ensure they remain effective and aligned with current rules.

Remittance and fund planning

Although the remittance basis has largely been removed, there are still planning opportunities around existing offshore funds, including the use of transitional provisions such as the Temporary Repatriation Facility.

Relocation planning

For those moving to or from the UK, the timing of arrival, departure and changes in residency status can significantly impact tax outcomes. Advance planning can help optimise the use of available reliefs and avoid unintended liabilities.

HMRC compliance and reporting

With increased complexity and scrutiny, ensuring accurate reporting of worldwide income and gains is essential. Taking a proactive approach to compliance helps reduce risk and provides clarity as rules continue to evolve.

Non-dom tax planning under new rules

Navigating the new regime requires proactive, tailored planning to ensure your structures and affairs remain efficient and aligned with your long-term objectives. Key actions include:

Reviewing existing structures
Assess whether current holding structures, investments and arrangements remain effective under a residence-based system, and identify areas where changes may be required
Trust restructuring
Revisit offshore trust arrangements to determine whether they continue to deliver the intended tax outcomes, and consider restructuring where protections have been reduced or removed
Asset planning
Evaluate the ownership and location of assets to manage exposure to UK tax, including income tax, capital gains tax and Inheritance Tax over the longer term
Residency review
Confirm your UK and non-UK residency status and consider timing of arrivals, departures and disposals to optimise available reliefs, including eligibility for the four-year FIG regime
Making the most of transitional opportunities
Identify opportunities under transitional rules, including the Temporary Repatriation Facility, to reorganise historic foreign income and gains efficiently

Taking early advice can help ensure you make informed decisions and avoid unintended tax exposure under the new rules. If you would like to discuss how these changes affect your position, please get in touch with our Personal Tax specialists.

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International tax expertise for globally mobile individuals

Our private client advisory team supports internationally mobile individuals, including international families, entrepreneurs and investors with complex cross-border interests. We provide coordinated, practical advice that reflects the interaction between UK and overseas tax regimes, helping you manage risk, remain compliant and structure your affairs efficiently across jurisdictions.

Working closely with our international network, we deliver integrated cross-border tax support tailored to your personal and commercial objectives. Our specialists combine technical expertise with a clear understanding of global mobility challenges, advising on evolving rules and ensuring your tax position remains robust in a changing landscape. Our approach is grounded in experienced professionals with recognised specialist credentials, supported by a dedicated private client advisory team.

This guidance has been updated for 2026 .

For internationally mobile individuals and families, understanding the new rules and transitional reliefs will be key to effective tax planning. The four-year window is a great tax planning opportunity for those who have non-UK income and or non-UK gains.

Nikita Cooper, Tax Director

Speak to our international tax specialists

The UK’s non-dom tax changes represent one of the most significant shifts in personal taxation in recent years, particularly for internationally mobile individuals with cross-border income, assets or family connections. Whether you are newly arriving in the UK or have historically relied on non-dom status, understanding how the new rules apply to your circumstances is essential to managing your tax position effectively.

Our international tax specialists work closely with individuals affected by these changes to provide clear, practical advice tailored to their situation, helping you navigate the transition, identify planning opportunities and ensure ongoing compliance with evolving UK tax requirements.

For an international tax consultation today, complete the form below.

What FAQs do our experts receive?

What is non-dom status?

Non-domicile (“non-dom”) status applied to UK residents whose permanent home (domicile) was outside the UK. Under the previous rules, it allowed individuals to be taxed on UK income and gains, while foreign income and gains were only taxed if brought into the UK.

What happened to non-dom status after April 2025?

From 6 April 2025, the non-dom regime was abolished and replaced with a residence-based system. The remittance basis no longer applies, and most UK residents are now taxed on their worldwide income and gains as they arise, subject to limited transitional rules.

What is the FIG regime?

The Foreign Income and Gains (FIG) regime is a new relief for individuals who become UK tax resident after at least 10 years of non-UK residence. It allows qualifying individuals to receive foreign income and gains free from UK tax for their first four years of UK residence, regardless of whether those funds are brought to the UK.

How is UK tax residency determined?

UK tax residency is determined using the Statutory Residence Test (SRT), which considers factors such as the number of days spent in the UK, whether you have a home in the UK, and your personal or economic ties to the UK.

Will overseas income still be tax free for non-doms?

Overseas income is no longer generally tax free. From April 2025, UK residents are taxed on worldwide income, although qualifying individuals can benefit from up to four years of exemption under the FIG regime.

How does the remittance basis currently work?

Under the previous regime (ending in April 2025), the remittance basis allowed non-doms to pay UK tax on UK income and gains, while foreign income and gains were only taxed if remitted (brought) into the UK.