UK Non Dom

Section 1 — Quick Reference

Quick Reference

Field	Value
Country	UK
Old regime	Remittance basis (domicile-based) — abolished from April 2025
New regime	4-year Foreign Income and Gains (FIG) exemption
FIG effective	From 6 April 2025
FIG duration	First 4 tax years of UK tax residence
FIG rate on foreign income/gains	0% for qualifying new residents
After 4 years	Worldwide basis — all income/gains taxed in UK
Primary legislation	Finance Act 2025 (amending ITTOIA 2005 and TCGA 1992)
Tax authority	HMRC (gov.uk)
Verified by	Live status: https://openaccountants.com/skills/uk-non-dom

Section 2 — The New FIG Regime (From April 2025)

• Abolition of remittance basis — The UK abolished the remittance basis / domicile-based non-dom regime from 6 April 2025.
• Replacement regime — The 4-year Foreign Income and Gains (FIG) exemption.
• Who qualifies for FIG — Any individual who becomes a UK tax resident on or after 6 April 2025 AND was not UK tax resident in any of the preceding 10 tax years.
• What is exempt under FIG — All foreign income (dividends, interest, rent, employment income from foreign employer) arising while the individual is in their first 4 years of UK tax residence; all foreign capital gains arising while in the first 4 years.
• What is NOT exempt under FIG — UK-source income and gains — taxed normally regardless of FIG status; foreign income/gains arising AFTER the 4-year window.
• FIG window is absolute — No extension, no exceptions. After 4 tax years of UK residence, the individual is taxed on worldwide basis from year 5 onwards.
• No election needed — FIG applies automatically. The individual may elect OUT (e.g. if they want to use foreign losses against UK income) but there is no requirement to file a special claim.

Section 3 — Transitional Provisions: Existing Non-Doms

For individuals who were already using the remittance basis before 6 April 2025:

• Option 1 — Temporary Repatriation Facility (TRF) — A 3-year window (2025/26, 2026/27, 2027/28) to bring previously unremitted foreign income and gains to the UK at a reduced flat rate.
• TRF reduced flat rate 2025/26 and 2026/27 — 12% % (amounts remitted in 2025/26 and 2026/27) (https://www.gov.uk/hmrc-internal-manuals/residence-domicile-and-remittance-basis/rdrm73400)
• TRF reduced flat rate 2027/28 — 15% % (amounts remitted in 2027/28) (https://www.gov.uk/hmrc-internal-manuals/residence-domicile-and-remittance-basis/rdrm73400)
• After TRF window — After 2027/28, unremitted pre-2025 income remitted to the UK is taxed at full normal rates.
• Option 2 — Rebasing of foreign capital gains — Foreign assets (other than non-UK real estate) can be rebased to their 5 April 2019 market value for CGT purposes. Only applies to individuals who claimed the remittance basis in 2016/17 or earlier.

Section 4 — Before April 2025: Remittance Basis (History)

• Old regime mechanics — UK residents who were not domiciled in the UK could elect for the remittance basis. Foreign income and gains were taxed only when remitted to the UK.
• Annual remittance basis charge (after 7 years UK residence) — £30,000 GBP (after 7 years UK residence)
• Annual remittance basis charge (after 12 years UK residence) — £60,000 GBP (after 12 years UK residence)
• Deemed domicile after 15 years — After 15 years UK residence: deemed domiciled — remittance basis no longer available.

This system is now history for new residents. The FIG regime replaced it.

Section 5 — Overseas Workday Relief (OWR)

• Overseas Workday Relief (OWR) — OWR continues under the new regime. OWR allows UK-resident employees to exclude from UK tax the proportion of employment income attributable to non-UK workdays (days physically working outside the UK).
• OWR availability under FIG regime — Under the new FIG regime, OWR is available for the first 4 years of UK residence (aligned with FIG), without the remittance condition that applied under the old regime.
• UK-taxable employment income formula — UK-taxable employment income = Total employment income × (UK workdays / Total workdays)
• Recordkeeping requirement — Requires keeping a contemporaneous workday log.

Section 6 — Sources

• Finance Act 2025, Part X (FIG provisions)
• HMRC: gov.uk/guidance/non-domicile-rules
• HMRC RDRM (Residence, Domicile and Remittance Manual)

Working paper only. The FIG regime is new (effective April 2025). HMRC guidance is still being finalised. Engage a UK tax adviser for any individual relying on FIG — particularly those in years 3-4 approaching the worldwide basis transition.