International Tax UK 2026/27 — Moving Abroad, Expats, Non-Doms and Digital NomadsNon-Domicile Tax Status Changes UK — What's Happening and Who's Affected
The UK is abolishing non-domicile tax status from April 2025. What the changes mean, who's affected, and the new residence-based system.
The UK’s non-domicile tax regime — which allowed wealthy residents with foreign domicile to shelter overseas income from UK tax — is being replaced from April 2025. This is one of the most significant tax changes in decades.
What Is Non-Dom Status?
| Concept | Explanation |
|---|
| Domicile | Your permanent home — usually inherited from your father at birth |
| Tax residence | Where you’re physically resident for tax purposes |
| Non-dom | UK tax resident, but domiciled (permanent home) abroad |
| Remittance basis | Only pay UK tax on foreign income/gains brought into the UK |
| Arising basis | Pay UK tax on worldwide income (what most UK residents pay) |
How the Old System Worked
| UK residence period | Remittance basis charge |
|---|
| Under 7 of last 9 years | Free |
| 7 of last 9 years | £30,000/year |
| 12 of last 14 years | £60,000/year |
| 15 of last 20 years | Deemed domiciled — lose non-dom benefits |
The New System (From April 2025)
Foreign Income and Gains (FIG) Regime
| Feature | Detail |
|---|
| Who qualifies | Anyone who has been non-UK resident for 10+ consecutive years before arriving |
| Duration | 4 years from becoming UK resident |
| What’s exempt | Foreign income and foreign gains — not taxed in the UK |
| Remittance | Can bring foreign income/gains to the UK tax-free during the 4 years |
| After 4 years | Taxed on worldwide income like any other UK resident |
| Cost | No annual charge — it’s free for 4 years |
Comparison: Old vs New
| Feature | Old non-dom regime | New FIG regime |
|---|
| Qualification | Domicile abroad (often inherited) | 10+ years non-UK residence before arrival |
| Duration | Up to 15 years (with charges) | 4 years only |
| Annual charge | £30,000–£60,000 | None |
| Foreign income treatment | Untaxed if not remitted | Untaxed for 4 years (then worldwide) |
| Can bring money to UK? | Only if willing to pay tax | Yes — tax-free for 4 years |
| After time limit | Deemed domiciled (worldwide tax) | Worldwide tax |
Transitional Arrangements
Temporary Repatriation Facility (TRF)
For existing non-doms with overseas income/gains from before April 2025:
| Year | Tax rate on repatriated income |
|---|
| 2025/26 | 12% |
| 2026/27 | 12% |
| 2027/28 | 15% |
| After 2027/28 | Full UK tax rates |
This allows existing non-doms to bring historic overseas wealth into the UK at a significantly reduced rate during the transition period.
CGT Rebasing
| Feature | Detail |
|---|
| What | Existing non-doms can rebase the value of foreign assets to their 5 April 2017 value |
| Effect | Only gains after that date are taxable when assets are sold |
| Who benefits | Non-doms with large gains built up before April 2017 |
Inheritance Tax Changes
| Feature | Old rules | New rules (from April 2025) |
|---|
| Basis | Domicile — non-UK domiciled = only UK assets taxed | Residence — 10-year look-back |
| When worldwide assets taxed | Only if UK domiciled or deemed domiciled | After 10 years of UK residence |
| Leaving the UK | Worldwide assets fall out of IHT after 3 years | Falls out after 10 years of non-residence |
| Excluded property trusts | Foreign assets in trust shielded from IHT | No longer fully protected |
IHT Tail Period
When you leave the UK, your worldwide assets remain in scope for IHT based on how long you were resident:
| Years of UK residence | IHT “tail” after leaving |
|---|
| Under 10 years | 3 years |
| 10–13 years | 3 years |
| 14 years | 4 years |
| 15 years | 5 years |
| 20+ years | 10 years |
Who Is Affected?
| Group | Impact |
|---|
| Existing long-term non-doms | Lose remittance basis — now taxed on worldwide income |
| Wealthy new arrivals | 4-year FIG regime (shorter than old system but free) |
| Non-dom trust structures | IHT protection reduced — review trusts urgently |
| Short-term visitors (under 4 years) | May benefit from clearer, free FIG regime |
| Born in UK, returned | Generally can’t use FIG if originally UK-domiciled |
| UK residents (domiciled) | No change — already taxed on worldwide income |
What Should Affected People Do?
| Action | Who | When |
|---|
| Review trust structures | Existing non-doms with offshore trusts | Now |
| Consider TRF | Non-doms with historical overseas income | 2025–2028 |
| CGT rebasing election | Non-doms with pre-2017 foreign assets | At point of sale |
| IHT planning | Anyone near the 10-year residence threshold | Now |
| Seek specialist tax advice | Everyone affected | Immediately |
| Review residency plans | Those considering leaving the UK | Before decisions are finalised |
Summary
| Change | Detail |
|---|
| Non-dom status | Abolished from April 2025 |
| Replacement | 4-year FIG regime for new arrivals (10+ years non-resident) |
| Transition | TRF: bring in old money at 12%–15% (2025–2028) |
| CGT | Rebasing to April 2017 values available |
| IHT | Moving to residence-based system with 10-year look-back |
| Trust protection | Significantly reduced |
| Key action | Take specialist tax advice |
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