Tax

Non-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