The UK’s «non-domiciled» regime had been standing since 1799. On 6 April 2025, it stopped existing. For anyone who had London on their radar for its old treatment of foreign income, this changes the equation entirely — not necessarily for the worse, but it changes shape.
What existed, and why it ended
The old system let anyone without a «domicile» in the UK (a legal concept distinct from residency, tied more to family origin and intention of permanent settlement) be taxed only on UK-source income and gains, keeping foreign income outside UK income tax as long as it wasn’t remitted to the UK — the so-called «remittance basis.» It could be maintained indefinitely, with an annual charge kicking in after a certain number of years of residency. The regime became politically untenable, seen as a privilege for wealthy foreign residents in London, and the government scrapped it.
Its replacement: the FIG regime, with a built-in expiry date
The new Foreign Income and Gains (FIG) regime starts from a different logic: instead of a potentially indefinite benefit, it offers a window of just four years.
- It applies to anyone becoming a UK tax resident after having been a non-resident for at least the previous ten consecutive years.
- During those first four years of residency, foreign-source income and gains are exempt from UK tax — with no need to keep them outside the country, unlike the old remittance system.
- It must be actively claimed each tax year you want it to apply; it isn’t automatic.
- There’s also a Temporary Repatriation Facility (TRF) for those who had unremitted foreign income accumulated under the old regime: they can bring it into the UK at a reduced rate — 12% for the 2025/26 and 2026/27 tax years, rising to 15% in 2027/28 — instead of the full marginal rate.
What changes for anyone considering London now
The most important practical difference from the old regime isn’t just the duration — four years versus potentially decades — it’s the philosophy: the new system is designed to attract talent and capital temporarily with clear rules from day one, not to offer a long-term tax shelter. Anyone planning a multi-year move to the UK with significant foreign income (dividends from a company outside the country, rent elsewhere, investment gains) has to accept that, past the fourth year, that income is taxed in the UK just like any other resident’s.
For shorter, well-planned stays — projects of four years or less, or someone who can stagger the repatriation of accumulated foreign income while the TRF lasts — the FIG regime remains a genuine savings window, just one that needs to be planned with an expiry date in mind from day one, not treated as something to figure out later.
In the comments: if you moved to the UK after April 2025 and claimed the FIG regime, share how the annual claim process went and whether you’ve used the Temporary Repatriation Facility to bring in accumulated income from the old regime. It’s such a new regime that real shared experiences barely exist yet.
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Sources: HMRC and tax firm analyses of the non-dom reform (KPMG, Saffery, BDO, Deloitte), in force since 6 April 2025. This isn’t tax advice — eligibility for the FIG regime and the Temporary Repatriation Facility depends on your specific residency history.