How the UK taxes the foreign income and gains of people who used to be non-doms, and of new arrivals, for tax year 2026/27 (6 April 2026 to 5 April 2027), after Finance Act 2025 ended the remittance basis. Covers the 4-year foreign income and gains (FIG) regime for people who were non-resident fo…
United Kingdom · tax year 2026 · changed 27 Oct 2026
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Sources read 24 Oct 2026 for tax year 2026
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| Item | Rate or amount | Year | Source |
|---|---|---|---|
| FIG regime: non-resident years needed before the first qualifying year | 10 consecutive tax years | 2025/26 on | https://www.legislation.gov.uk/ukpga/2005/5/section/845B |
| FIG regime: length | First qualifying year plus the next 3 tax years | 2025/26 on | https://www.legislation.gov.uk/ukpga/2005/5/section/845B |
| FIG regime: minimum age at 6 April | 10 | 2025/26 on | https://www.legislation.gov.uk/ukpga/2005/5/section/845B |
| FIG claim deadline | 12 months from 31 January after the tax year (31 January 2029 for 2026/27) | 2026/27 | https://www.legislation.gov.uk/ukpga/2005/5/section/845A |
| Overseas Workday Relief limit per qualifying year | Lower of 30% of qualifying employment income or £300,000 | 2025/26 on | https://www.gov.uk/hmrc-internal-manuals/employment-income-manual/eim43600 |
| TRF charge, designated in 2025/26 or 2026/27 return | 12% | 2025/26, 2026/27 | https://www.legislation.gov.uk/ukpga/2025/8/schedule/10 |
| TRF charge, designated in 2027/28 return | 15% | 2027/28 | https://www.legislation.gov.uk/ukpga/2025/8/schedule/10 |
| TRF designation election deadline | 12 months from 31 January after the tax year (31 January 2029 for 2026/27) | 2026/27 | https://www.legislation.gov.uk/ukpga/2025/8/schedule/10 |
| Rebasing date | Market value on 5 April 2017 | disposals from 6 April 2025 | https://www.legislation.gov.uk/ukpga/2025/8/schedule/11 |
| IHT long-term UK resident | UK resident in at least 10 of the previous 20 tax years | 2025/26 on | https://www.legislation.gov.uk/ukpga/1984/51/section/6A |
| IHT tail: consecutive non-resident years to fall out | 3 (13 or fewer resident years), then one more per resident year: 14 needs 4, up to 20 needs 10 | 2025/26 on | https://www.legislation.gov.uk/ukpga/1984/51/section/6A |
| Personal allowance (lost on a FIG claim or OWR election) | £12,570 | 2026/27 | https://www.legislation.gov.uk/ukpga/2007/3/section/35 |
| Basic rate limit | £37,700 at 20%; higher rate 40%; additional rate 45% over £125,140 | 2026/27 | https://www.legislation.gov.uk/ukpga/2007/3/section/10 |
| Remittance basis charge (£30,000 / £60,000 up to 2024/25) | Abolished; no charge | 2025/26 on | https://www.gov.uk/hmrc-internal-manuals/residence-domicile-and-remittance-basis/rdrm32210 |
uk-statutory-residence-test for each year in the look-back. For the FIG test, a split year and a year in which a treaty makes the person resident elsewhere still count as UK resident years (RFIG44000). A look-back reaching 2012/13 or earlier uses the pre-SRT rules: refer it.| Item | Rate or amount | Year | Source |
|---|---|---|---|
| FIG regime: non-resident years needed before the first qualifying year | 10 consecutive tax years | 2025/26 on | https://www.legislation.gov.uk/ukpga/2005/5/section/845B |
| FIG regime: length | First qualifying year plus the next 3 tax years | 2025/26 on | https://www.legislation.gov.uk/ukpga/2005/5/section/845B |
| FIG regime: minimum age at 6 April | 10 | 2025/26 on | https://www.legislation.gov.uk/ukpga/2005/5/section/845B |
| FIG claim deadline | 12 months from 31 January after the tax year (31 January 2029 for 2026/27) | 2026/27 | https://www.legislation.gov.uk/ukpga/2005/5/section/845A |
| Overseas Workday Relief limit per qualifying year | Lower of 30% of qualifying employment income or £300,000 | 2025/26 on | https://www.gov.uk/hmrc-internal-manuals/employment-income-manual/eim43600 |
| TRF charge, designated in 2025/26 or 2026/27 return | 12% | 2025/26, 2026/27 | https://www.legislation.gov.uk/ukpga/2025/8/schedule/10 |
| TRF charge, designated in 2027/28 return | 15% | 2027/28 | https://www.legislation.gov.uk/ukpga/2025/8/schedule/10 |
| TRF designation election deadline | 12 months from 31 January after the tax year (31 January 2029 for 2026/27) | 2026/27 | https://www.legislation.gov.uk/ukpga/2025/8/schedule/10 |
| Rebasing date | Market value on 5 April 2017 | disposals from 6 April 2025 | https://www.legislation.gov.uk/ukpga/2025/8/schedule/11 |
| IHT long-term UK resident | UK resident in at least 10 of the previous 20 tax years | 2025/26 on | https://www.legislation.gov.uk/ukpga/1984/51/section/6A |
| IHT tail: consecutive non-resident years to fall out | 3 (13 or fewer resident years), then one more per resident year: 14 needs 4, up to 20 needs 10 | 2025/26 on | https://www.legislation.gov.uk/ukpga/1984/51/section/6A |
| Personal allowance (lost on a FIG claim or OWR election) | £12,570 | 2026/27 | https://www.legislation.gov.uk/ukpga/2007/3/section/35 |
| Basic rate limit | £37,700 at 20%; higher rate 40%; additional rate 45% over £125,140 | 2026/27 | https://www.legislation.gov.uk/ukpga/2007/3/section/10 |
| Remittance basis charge (£30,000 / £60,000 up to 2024/25) | Abolished; no charge | 2025/26 on | https://www.gov.uk/hmrc-internal-manuals/residence-domicile-and-remittance-basis/rdrm32210 |
The TRF rates are set by FA 2025 Sch 10 para 1(8): "12% of the amount of that capital" for 2025/26 or 2026/27, and "15%" for 2027/28. There is no TRF after 2027/28.
What a FIG claim relieves. Qualifying foreign income (ITTOIA 2005 s845H) that arises on or after 6 April 2025: profits of a trade carried on wholly outside the UK, overseas property profits, foreign interest, dividends from non-UK companies, most foreign pensions, royalties and offshore income gains. Foreign gains are relieved by a separate foreign gain claim (TCGA 1992 Schedule D1). Not covered: UK income and gains, foreign employment income (use OWR), and any FIG that arose before 6 April 2025, "whether or not he remits them" in the window (RFIG44000).
How the claim works (s845A). It must be made in a return, source by source, and quantified. The relief is deducted at Step 2 of ITA 2007 s23, and only from qualifying foreign income (s845A(3A), added by Finance Act 2026). A smaller claim relieves only the amount claimed. A wrongly quantified claim is still valid; an unquantified one is not (RFIG42100). There is no cap and no automatic relief. Relieved amounts can be brought to the UK at any time without further UK tax. Each year needs its own claim.
What a claim costs. A foreign income claim, a foreign gain claim or an OWR election for a year removes, for that year (ITTOIA ss845C to 845G, s845E for the allowances; TCGA s1K; RFIG43000; GOV.UK "Allowances you'll lose"):
The cost applies even when the claim covers one small source. Brought-forward overseas losses are used against that business before the relief. Adjusted net income for the child benefit charge and tax-free childcare still counts all foreign income. A foreign income claim also cuts the maximum pension contribution relief by the relieved foreign income that counts as relevant UK earnings, but never below the £3,600 basic amount (s845F(2); FA 2004 s190(4)). UK losses are unaffected.
Overseas Workday Relief (ITEPA 2003 Part 2 Chapter 5C). A qualifying new resident employee can elect and claim relief on the part of employment income for duties performed outside the UK. No FIG claim is needed and the money no longer has to stay offshore. The limit for each qualifying year is the lower of 30% of the qualifying employment income or £300,000, counted across all years in which that year's earnings are taxed, such as a later bonus (EIM43600). Earnings taxed before the employment year cannot use it. Transitional rules (EIM43605): an arrival in 2023/24 or 2024/25 who used OWR on the remittance basis gets OWR without the limit for years ending before 6 April 2028; a 2022/23 arrival who used OWR gets none for 2025/26. Earnings for remittance basis years keep the old OWR rules.
Old money: pre-6 April 2025 FIG. FIG that arose to a remittance basis user before 6 April 2025 "will continue to be taxed at the usual tax rates if they are remitted to the UK on or after 6 April 2025, unless these amounts are designated under the temporary repatriation facility" (HS264). The old remittance rules still decide what a remittance is (money or assets brought in, used for UK services or debts, benefits to relevant persons such as a spouse, minor children and close companies), and mixed fund ordering still applies. Remitted foreign dividends are taxed at the normal rates, not the dividend rates, with no dividend allowance. Foreign tax credit is due only on the same proportion of the foreign tax as the part of the income remitted (HS264). Business investment relief claims end after 5 April 2028.
The TRF (FA 2025 Sch 10). "Qualifying overseas capital" can be designated in the 2025/26, 2026/27 or 2027/28 return: pre-6 April 2025 FIG, amounts of uncertain origin in a mixed fund, capital payments and benefits from non-UK trusts matched to pre-2025 FIG, and assets derived from such FIG. Partial designation is allowed and nothing has to be brought in. Once the charge is paid the capital can be remitted later without further tax, and designated capital comes out of a mixed fund first. The charge is "charged as if they were amounts of income tax" (para 9), but HMRC treats it as a charge on capital: no foreign tax credit, no effect on adjusted net income, bands or payments on account, and earlier remittance basis charges cannot be set against it (RDRM73400). Foreign income is converted at the rate on 6 April of the designation year (6 April 2026 for 2026/27); foreign gains at the rate on disposal (HS264). Money taken from offshore to pay the charge is itself a remittance unless designated. Pre-2025 FIG invested in exempt property or in UK companies under business investment relief can be designated without disposing of the property or removing the investment (HS264). The charge cannot frank Gift Aid (RDRM73400). Overpayment relief is not available for a designation election, because it covers only income tax, CGT, Class 4 NIC and corporation tax (RDRM73320).
Rebasing to 5 April 2017 (FA 2025 Sch 11 para 1). On a disposal on or after 6 April 2025 the gain is computed from market value on 5 April 2017 if all of these hold: the asset was held on 5 April 2017; it "was not situated in the United Kingdom at any time in the period beginning with 6 March 2024 and ending with 5 April 2025"; the person was never UK domiciled (including deemed domicile under ITA 2007 s835BA) before 2025/26; and they made a remittance basis claim under ITA s809B for at least one year from 2017/18 to 2024/25 in which the remittance basis did not apply automatically. It applies despite the spouse no-gain/no-loss rule and follows share reorganisations. Para 2 carves out assets in the UK only for public access, repairs or sale, personal clothing, footwear, jewellery or watches, the under-£1,000 notional remittance rule, or temporary importation. Para 3: the person can elect out for a disposal, and the election "is irrevocable". Elect out when original cost beats the 2017 value. Para 4 amends the separate 2017 rebasing for deemed domiciliaries (refer). Rebasing changes only the base cost; the gain is taxed as it arises.
Inheritance tax (IHTA 1984 s6A). Long-term UK resident "at all times in a tax year if they were UK resident for at least 10 of the previous 20 tax years". Not long-term resident after 10 consecutive non-resident years in the previous 19, or after the "required number" of consecutive non-resident years ending last year. Count the resident years in the 20 tax years ending with the last resident year: 13 or fewer needs 3, 14 needs 4, and so on to 20, which needs 10. After 10 years away the count resets. HMRC transitional rules: someone without UK domicile or deemed domicile on 30 October 2024, non-resident for 2025/26 and not returning, is not long-term resident; someone deemed domiciled on 30 October 2024 who leaves the same way drops out after 3 years. Residence for 2012/13 and earlier is decided "as it would have been determined for income tax purposes for that tax year", and from 2013/14 by the statutory residence test (s6A(5)). Section 6B modifies the test for young persons; ss267ZC to 267ZE allow an election in. Any IHT computation is a refer case.
Trusts (pointer only). Overseas assets in a trust the person set up or added to are within IHT "even when you were not a long-term UK resident", except trust assets placed in trust while non-UK domiciled that were overseas on 30 October 2024 and at death (GOV.UK). Settlor and beneficiary charges, capital payment matching, transfer of assets abroad and TRF designation of trust amounts are refer cases. Tell trustees when long-term residence status changes.
uk-foreign-tax-and-withholding for credit relief.uk-statutory-residence-test.Leila was not UK resident in any of the 10 tax years to 2025/26 and is UK resident from 6 April 2026, outside Scotland. In 2026/27 she has a UK salary of £60,000 and overseas rental profit of £40,000, with no foreign tax. She is a qualifying new resident for 2026/27.
name: Qualifying new resident, salary 60,000 and foreign rent 40,000, claim vs no claim (2026/27)
inputs:
uk_salary: 60000
foreign_rent: 40000
personal_allowance: 12570
basic_band: 37700
steps:
- taxable_no_claim: uk_salary + foreign_rent - personal_allowance
- tax_no_claim: min(taxable_no_claim, basic_band) * 0.20 + max(taxable_no_claim - basic_band, 0) * 0.40
- taxable_claim: uk_salary
- tax_claim: min(taxable_claim, basic_band) * 0.20 + max(taxable_claim - basic_band, 0) * 0.40
- saving: tax_no_claim - tax_claim
expected:
taxable_no_claim: 87430
tax_no_claim: 27432
tax_claim: 16460
saving: 10972
Nida used the remittance basis up to 2024/25. She holds £30,000 of 2022/23 foreign income offshore and is UK resident in 2026/27. She is an additional rate taxpayer.
name: TRF on 30,000 of pre-2025 foreign income, 12% vs 15% vs remitted at 45%
inputs:
old_fig: 30000
steps:
- trf_2026_27: old_fig * 0.12
- trf_2027_28: old_fig * 0.15
- cost_of_waiting: trf_2027_28 - trf_2026_27
- undesignated_tax: old_fig * 0.45
- saving_vs_undesignated: undesignated_tax - trf_2026_27
expected:
trf_2026_27: 3600
trf_2027_28: 4500
cost_of_waiting: 900
undesignated_tax: 13500
saving_vs_undesignated: 9900
HMRC's own case (EIM43600, Example 4). Sergei is a qualifying new resident for 2025/26 and makes an OWR election. He earns £500,000 for 2025/26 and 40% of his duties are outside the UK: £200,000 of qualifying foreign employment income. Relief is the lower of £300,000 and 30% of £500,000 (£150,000), so £150,000. In 2026/27 he receives a £100,000 bonus for 2025/26 duties. His 2025/26 qualifying employment income charged to tax is now £600,000; the limit is the lower of £300,000 and £180,000, less £150,000 already claimed. He claims £30,000 in his 2026/27 return.
name: OWR limit across two tax years for one qualifying year (EIM43600 Example 4)
inputs:
earnings_y1: 500000
bonus_y2: 100000
overseas_share: 0.40
cap: 300000
steps:
- qfei_y1: earnings_y1 * overseas_share
- relief_y1: min(qfei_y1, min(cap, earnings_y1 * 0.30))
- limit_total: min(cap, (earnings_y1 + bonus_y2) * 0.30)
- relief_y2: min(bonus_y2 * overseas_share, limit_total - relief_y1)
expected:
qfei_y1: 200000
relief_y1: 150000
limit_total: 180000
relief_y2: 30000
Not yet confirmed: the 2026/27 SA109 box numbers for the TRF and FIG claims; the 2026/27 Self Assessment dates as printed by GOV.UK (pattern applied); the RFIG42100 quantification rule, carried from version 1.0 but not re-read; the remittance basis charge figures (RDRM32210) and deemed domicile Conditions A and B (ITA s835BA), kept as history only; the OWR claim time limit; the commencement of the age-10 test for 2025/26.
General reference, not advice on your facts. Check with a professional before you file or pay.
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