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.
·4 min read
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