Non-dom status ended on 6 April 2025 — here is the residence-based regime that replaced it
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The remittance basis that let UK residents shield foreign income from tax indefinitely no longer exists. A four-year exemption for genuinely new arrivals replaced it — and inheritance tax now follows residence, not domicile.
Non-dom status ended on 6 April 2025. The remittance basis — which let UK residents whose permanent home was abroad avoid UK tax on foreign income and gains they kept offshore, sometimes for decades — no longer exists in any form. It was replaced by a new regime based on how long someone has actually lived in the UK, not where they consider their permanent home to be. New arrivals now get four tax years of genuine relief on foreign income, then full UK tax on it afterwards, with no lifetime workaround left.
What actually ended on 6 April 2025
Before that date, a UK resident who was non-domiciled — broadly, someone whose permanent home was outside the UK even if they lived here — could claim the remittance basis. Foreign income and gains were only taxed if brought into the UK; left offshore, they could escape UK tax indefinitely, aside from an annual remittance basis charge of £30,000 after 7 of the previous 9 UK tax years, rising to £60,000 after 12 of the previous 14 years. After 15 of the previous 20 years' residence, a non-dom became "deemed domiciled" and lost access to the remittance basis altogether. All of this is now history — HMRC's own guidance confirms that "before 6 April 2025, UK residents who had their permanent home ('domicile') outside the UK did not have to pay UK tax on foreign income," using the past tense throughout, as set out on GOV.UK's guidance on non-domiciled residents. Domicile itself still matters for some legal purposes, but it has been removed as a connecting factor for UK tax.
The Foreign Income and Gains regime that replaced it
In its place is the 4-year Foreign Income and Gains (FIG) regime, available only to people who become UK tax resident after at least 10 consecutive tax years of non-UK residence. Genuinely new arrivals — not returning long-term expats — qualify for up to four tax years of 100% relief from UK tax on foreign income and gains, starting from the year they become UK resident (or 6 April 2025 if later). The mechanics and rationale for the change are set out in the government's policy summary on changes to the taxation of non-UK domiciled individuals and the accompanying HMRC/HM Treasury technical note.
| Old regime (before 6 April 2025) | New FIG regime (from 6 April 2025) | |
|---|---|---|
| Basis | Domicile | UK tax residence |
| Length of relief | Up to 15 years, with an annual charge after year 7 | 4 tax years, no charge |
| Qualifying test | Non-UK domicile | 10 consecutive years of prior non-UK residence |
| Cost of claiming | £30,000–£60,000 a year after year 7 | Loses Personal Allowance and CGT exempt amount for that year only |
| What happens after relief ends | Deemed domicile; remittance basis unavailable | Foreign income and gains taxed in full as they arise |
What claiming FIG relief costs you
The FIG regime is not automatic. It must be claimed on a tax return for each year, separately for income and for gains, and once claimed for a year it applies to all nominated foreign income or gains for that year — there is no cherry-picking which foreign receipts are covered. The trade-off is real: anyone who claims FIG relief forfeits the Income Tax Personal Allowance, worth £12,570 of tax-free income, and the Capital Gains Tax annual exempt amount, worth £3,000, for that tax year, whether or not they would otherwise have used them. For someone with substantial foreign income and modest UK income, giving up those allowances is a small price for shielding the foreign income entirely; for someone with little foreign income to protect, it may not be worth claiming at all in a given year.
A worked example: before and after the four years
Take someone who moves to the UK for the first time after more than a decade abroad, with £30,000 a year in foreign dividend income that stays in an overseas account. In each of their first four UK tax years, claiming FIG relief means that £30,000 is not taxed in the UK at all — a saving of several thousand pounds a year in Income Tax that would otherwise apply, set against forfeiting the £12,570 Personal Allowance for that year. Under the old rules, an equivalent long-stay non-dom in years 8 to 12 of UK residence would instead have paid a flat £30,000 remittance basis charge just to keep that same income sheltered — often more than the tax saved. From year five onward under the new rules, that same £30,000 of foreign dividend income is simply taxed in the UK exactly as if it were a UK dividend, with no remittance basis, no charge-based workaround and no distinction based on where the money physically sits.
Bringing in money earned under the old rules
Anyone who built up unremitted foreign income or gains under the old remittance basis before 6 April 2025 is not simply left exposed to full tax on brining that money to the UK. A Temporary Repatriation Facility (TRF) runs for three tax years — 2025/26, 2026/27 and 2027/28 — letting former remittance-basis users designate old, already-earned foreign income and gains and pay a flat rate instead of normal Income Tax or Capital Gains Tax rates on it: 12% in 2025/26 and 2026/27, rising to 15% in 2027/28, as confirmed in the HMRC technical note linked above. Once designated and the flat charge paid, that money can be brought into and spent in the UK freely, which is a materially better outcome than leaving it offshore and untaxed forever, since that option no longer exists under any circumstances.
Inheritance Tax: domicile is gone here too
The same 6 April 2025 reform moved Inheritance Tax from a domicile basis to a residence basis. Someone is now a "long-term UK resident" if they have been UK tax resident for at least 10 of the previous 20 tax years, and once that threshold is crossed, their worldwide assets — not just UK ones — are within scope for UK Inheritance Tax on death or on lifetime transfers, exactly as for a UK domiciled person. Leaving the UK does not switch this off immediately either: depending on how long someone was UK resident, the "tail" of IHT exposure after departure can run for up to 10 tax years before long-term resident status is lost, full detail on both points is in GOV.UK's guidance on Inheritance Tax for long-term UK residents. This is arguably a bigger practical change than the income tax reform for anyone with substantial assets held outside the UK, since it can apply even to people who never previously thought of themselves as at risk of UK Inheritance Tax at all.
Who this actually affects
- Genuinely new arrivals to the UK with significant foreign income or gains benefit from a real, if time-limited, four-year exemption with no annual charge attached.
- Long-term UK residents who previously relied on non-dom status lose that shelter completely once their four years (if they ever had them) are used up — there is no fallback remittance basis at any length of residence any more.
- Anyone with substantial non-UK assets who has lived in the UK for years, including some who never considered themselves "non-dom" in the popular sense, should check their position against the new long-term residence test for Inheritance Tax specifically, since the assets in scope are worldwide, not local.
- This article does not cover offshore trust structures set up before 6 April 2025, which carry their own transitional rules not addressed here.
Sources
- GOV.UK: Tax on foreign income — non-domiciled residents
- GOV.UK: 2024 non-UK domiciled individuals policy summary
- HM Treasury/HMRC: Technical note — Reforming the taxation of non-UK domiciled individuals
- GOV.UK: Inheritance Tax if you're a long-term UK resident
- GOV.UK: Maintaining the annual exempt amount for Capital Gains Tax
This is general information, not tax advice. Non-dom and residence rules interact with double taxation treaties, offshore trusts and individual immigration history in ways that vary enormously from person to person. Anyone affected should speak to a regulated tax adviser or refer to HMRC's own guidance before making decisions about foreign income, gains or estate planning.