Guide

The end of the non-dom regime: what replaced it

The remittance basis ended on 6 April 2025, and domicile stopped being the connecting factor for foreign income and gains. What exists in its place is residence based: a four-year relief for people arriving in the UK after a long period abroad, a time-limited facility that lets former remittance basis users bring older foreign income and gains onshore at a reduced rate, and an inheritance tax test that counts years of residence rather than domicile.

Published 30 August 2026. Checked against the cited sources on that date.

This guide describes published UK rules in general terms, as at 30 August 2026. It is not tax advice, and nothing here takes account of your circumstances. Decisions about residence, domicile and tax belong with your tax adviser.

What ended

For foreign income and gains arising on or after 6 April 2025, the remittance basis no longer exists. Before that date, a non-domiciled individual could claim the remittance basis and be taxed on foreign income and gains only to the extent they were brought into the UK. From that date, UK residents are taxed on the arising basis on their worldwide income and gains, unless a specific relief applies.

Domicile and deemed domicile were removed as the connecting factors for these purposes and replaced by tests based on residence. Domicile has not disappeared from the law altogether, and HMRC is explicit that it remains relevant in some places, but it is no longer the thing that decides how your foreign income and gains are taxed.

Residence is still determined by the statutory residence test, which works as it did before and is described in the guide to UK tax residence. The reliefs below are claimed, year by year, by people who qualify.

The four-year foreign income and gains regime

The four-year foreign income and gains regime, usually shortened to the FIG regime, gives 100 per cent relief on eligible foreign income and gains to people in their first four tax years of UK residence. To be a qualifying resident you must be UK resident under the statutory residence test and still within those first four years, following at least ten consecutive tax years of non-UK residence.

Three points about how it works in practice, all of them from the published guidance:

  • The four-year window is fixed and cannot be extended. If you leave and cease to be UK resident partway through, the years you were non-resident are simply not available; the remaining eligible years can still be claimed if you return within the window.
  • A claim is made for a tax year, in a self assessment return, and it has a deadline of its own.
  • Claiming has a cost. For a year in which you claim, you lose the tax-free allowances for income tax and capital gains tax: the personal allowance and the capital gains annual exempt amount. Foreign losses cannot be claimed for that year either.

Foreign employment earnings sit outside the FIG regime. They are dealt with by overseas workday relief, below.

The temporary repatriation facility

The FIG regime deals with money arising after the change. The temporary repatriation facility deals with money that arose before it, and that a former remittance basis user has kept offshore precisely because bringing it in would have triggered a charge.

The facility runs for three tax years: 2025 to 2026, 2026 to 2027, and 2027 to 2028. Within that window, a former remittance basis user can designate qualifying overseas capital in a return. Qualifying overseas capital includes pre-6 April 2025 foreign income and gains, and certain amounts held overseas where the source cannot now be established.

The charge on designation is 12 per cent of the amount designated for 2025 to 2026 and 2026 to 2027, and 15 per cent for 2027 to 2028. Once an amount has been designated and the charge paid, it can be brought to the UK without a further remittance charge. The facility closes after 2027 to 2028, and the rate rises in its final year, so the timing question is a real one. It is also a question for your tax adviser, not for a web page.

Capital gains rebasing

Alongside the facility there is a rebasing measure. Qualifying former remittance basis users may, on a disposal, use the 5 April 2017 market value of personally held foreign assets in place of original cost, subject to the conditions set out in the legislation and the published guidance. Eligibility turns on the individual's history of remittance basis use, so it is checked asset by asset and person by person.

Inheritance tax moved to a residence basis

From 6 April 2025, whether inheritance tax reaches your worldwide assets depends on long-term UK residence rather than domicile. An individual is a long-term UK resident if they have been UK resident in at least ten of the twenty tax years immediately before the tax year in which the chargeable event, including death, arises.

Long-term resident status does not end on the day you leave. It persists for between three and ten tax years after departure, depending on how long you were resident: HMRC's published examples give three years after leaving for someone who was resident for ten to thirteen years, and five years for someone resident for fifteen. Ten consecutive tax years of non-residence resets the test, so a returner starts counting again from the year of return.

This is the change with the longest memory. It is decided by a twenty-year residence history, which means it is decided by records that in most families were never kept with this test in mind.

Overseas workday relief

Overseas workday relief was retained and reformed rather than abolished. From 6 April 2025 it is available for four tax years, it no longer requires the income to be kept offshore, and it is subject to an annual financial limit for each qualifying year: the lower of £300,000 or 30 per cent of the qualifying employment income for that year.

What this means for your records

Every one of the rules above is applied for a tax year, and every one of them turns on residence history. The FIG regime asks whether you had ten consecutive non-resident years and which of your first four resident years this is. The temporary repatriation facility asks when income or gains arose, relative to a single date. The inheritance tax test asks how many of the last twenty tax years you were resident. None of this is decided by an opinion. It is decided by evidence, and the evidence is yours to hold.

That is where I am useful, and it is a narrow use. Not the determination, which belongs to your tax adviser: the records the determination will be made from.

  • Day counts, kept contemporaneously. Reconstructing a year of travel from boarding passes and card statements two years later is slow, expensive and disputable. The residence day counter counts days against the published statutory residence test rules and helps you keep your own record. It runs entirely in your browser, keeps nothing on the server, and lets you export what you have entered.
  • Timing evidence for foreign income and gains. The facility and the FIG regime both hinge on whether an amount arose before or after 6 April 2025. Statements, contract notes and distribution records that establish the date, held somewhere findable, are worth more later than they cost now.
  • A twenty-year residence history. The inheritance tax test looks back further than most people's filing does. It is worth writing down what is known now, while it is still known.
  • A map of who holds what. Most families in this position have a UK adviser, an adviser in another jurisdiction, a trustee, a bank and sometimes a company secretary, each holding part of the picture and none holding all of it. Writing down which adviser holds which record, and who can reach it, is covered in where your documents actually live.

The pattern I see most often is not that a record has been lost. It is that nobody can establish quickly enough what exists and who holds it, at exactly the moment a claim, a return or an enquiry requires it.

Sources

Related

How UK tax residence is decided sets out the statutory residence test the rules above depend on. Leaving the UK covers what changes on departure and what has to be kept. Where your documents actually live deals with custody and findability across advisers.

The residence day counter is the practical companion to this page. Other guides and tools are listed on the guides and tools pages.

Where a family wants the record itself held and kept current rather than assembled each time a claim or an enquiry needs it, that is a retained private digital office, and you can get in touch directly.