Since 6 April 2025, the remittance basis of taxation for non-UK domiciled individuals (non-doms) has been replaced by the Foreign Income and Gains (FIG) regime. This shift marks a significant change, as the new FIG regime is based on tax residence rather than domicile. Under the revised rules, almost all UK-resident individuals must report their foreign income and gains to HMRC, irrespective of whether they previously used the remittance basis or are now eligible for FIG relief.
For those former remittance basis users who no longer qualify for the new FIG relief, the treatment of newly arising foreign income and gains now aligns with the standard tax regime for UK residents. However, they will still be liable for tax on any pre-6 April 2025 FIG income and gains if they are remitted to the UK.
A key feature of the FIG regime is the 4-year FIG exemption for new UK residents. Individuals who have not been UK tax resident in any of the previous 10 tax years may opt to receive full tax relief on their FIG for up to four years. To claim this, individuals must submit a self-assessment return, with deadlines falling on 31 January in the second tax year following the relevant claim year.
Importantly, claims can be made selectively in any of the four years but must include quantified figures for income and gains; otherwise, tax will be due at standard rates. An individual’s ability to qualify for the 4-year FIG regime will be determined by whether they are UK resident under the Statutory Residence Test (SRT).
