UK Non-Dom Changes: The Four-Year FIG Regime

Information checked against HMRC guidance on 12 October 2026. This update explains rules already in force, including the changes introduced on 6 April 2025.

What changed for UK residents on 6 April 2025?

The remittance basis ended for new foreign income and gains from 6 April 2025. UK residents generally pay UK tax on worldwide income and gains as they arise, subject to available reliefs. Qualifying new residents can claim relief under the four-year foreign income and gains (FIG) regime. A foreign passport or a previous non-dom claim does not, by itself, establish eligibility.

The current rules separate three questions: whether you are UK tax resident, whether new foreign income or gains qualify for relief, and how any untaxed funds from earlier remittance-basis years are treated. Each needs the relevant dates and records.

Who can use the four-year FIG regime?

You must be UK resident under the Statutory Residence Test and within the first four tax years of UK residence following at least ten consecutive tax years of non-UK residence, subject to the regime's exclusions. The four-year window runs from the first UK-resident tax year. It is not four years from the day you first claim.

If you became UK resident before April 2025, only the remaining part of your qualifying window may be available from 2025/26. Skipping a claim or temporarily becoming non-resident does not extend that window. See HMRC's FIG eligibility guidance.

For an illustrative timeline, someone first UK resident in 2024/25 after the required ten non-resident tax years has a four-year window ending in 2027/28. The new relief could apply to qualifying amounts from 2025/26 to 2027/28, if the conditions are met and the appropriate claims are made. It does not retrospectively relieve 2024/25 income.

Claims, qualifying income and the effect on allowances

FIG relief requires a claim through Self Assessment for each tax year in which you want it. You identify the eligible foreign income sources and gains to be relieved. Qualifying amounts covered by a valid claim may be brought to the UK without a further UK tax charge. UK-source income is generally outside this relief; overseas employment income needs separate consideration under Overseas Workday Relief.

Claiming has costs as well as benefits. You lose the Personal Allowance and Capital Gains Tax annual exempt amount for the claim year, alongside certain other allowances and reliefs, and foreign-loss restrictions can apply. Compare the full tax position before deciding what to claim. HMRC's HS266 helpsheet explains the return pages, conditions and consequences.

Older offshore income and the Temporary Repatriation Facility

Foreign income and gains arising before 6 April 2025 in remittance-basis years remain a separate issue. Untaxed amounts can still create a UK charge when remitted. New FIG relief does not automatically shelter these historic funds, including when a former remittance-basis user returns to the UK.

The Temporary Repatriation Facility (TRF) allows eligible UK-resident former remittance-basis users to elect to designate qualifying overseas capital through Self Assessment. The charge depends on the tax year for which the designation is made:

Properly designated amounts can be remitted later without a further charge on those amounts. The end of 2027/28 is not a requirement to physically transfer every designated amount by 5 April 2028. Mixed accounts, assets bought with historic funds and trust payments need careful tracing. Read HMRC's HS264 guidance and its TRF charge guidance before making a designation.

Inheritance Tax, trusts and transitional asset rules

Inheritance Tax also changed on 6 April 2025. The scope for overseas assets is now principally linked to long-term UK residence, broadly residence in at least ten of the twenty tax years before the relevant tax year. Exposure can continue for three to ten years after departure, depending on the residence history and applicable rules. UK assets can remain within scope independently. Check HMRC's long-term residence guidance.

Domicile can still matter for earlier events, some treaty provisions and trust transitional rules. It should not be presented as the general current test for overseas assets. Relevant offshore-trust income protections also ended from 6 April 2025; settlor rules, any available FIG relief and historic income pools require separate assessment. See HMRC's explanation of when domicile remains relevant and the changes to protected foreign-source trust income.

Transitional rebasing can allow a 5 April 2017 market value for certain foreign assets, subject to detailed conditions concerning the individual, earlier remittance-basis use, ownership and asset location. It is not a general entitlement for every former non-dom. The enacted rules are in Finance Act 2025, Schedule 11.

What to prepare before discussing your position

• A year-by-year UK residence history, travel records and arrival or departure dates.
• Earlier tax returns and details of any remittance-basis claims.
• Foreign income, gains and losses by source and tax year, with supporting statements.
• Records identifying historic funds, later transfers and relevant asset purchases.
• Details of trusts, overseas structures, planned disposals and tax already paid abroad.

Accusolve is an AAT AML-supervised UK accountancy practice. We can discuss the UK tax and reporting work required, identify questions needing specialist input and agree the scope before starting. Use our UK arrival and departure planning or personal tax return and FIG support. If you remain non-UK resident, our non-resident tax advice explains the different starting point.

Questions about the non-dom changes