UK Non-Dom Abolished: The FIG Regime Complete Guide (2026)

The UK non-domicile regime — the tax rule that for over two centuries let wealthy foreigners living in Britain shield their offshore income from UK tax — was formally abolished on April 6, 2025. It was the single largest UK personal-tax reform in two generations, and it lands on a specific population: roughly 74,000 non-doms who had been claiming the remittance basis as of HMRC's last 2023 count, plus every HNWI globally who was considering the UK as a future residence.

The replacement — the 4-year Foreign Income and Gains (FIG) regime — is narrower, shorter, and fundamentally different in structure. Non-dom status was indefinite (up to 15 years on the remittance basis before deemed domicile kicked in). FIG is strictly 4 years. Non-dom status was based on an ancestry-and-intent concept (your father's domicile, your long-term intentions about where you'll die). FIG is based purely on residence history. Non-dom status sheltered foreign income only if it wasn't brought into the UK. FIG exempts foreign income and gains regardlessof remittance — but only for 4 years, and only for the narrow population that qualifies.

This guide covers the rules as they now operate, the transitional windows that close between now and April 2028, the Capital Gains Tax rebasing option, the Inheritance Tax residence-based reform (arguably the bigger shock for long-term UK residents), and the destinations people are actually choosing. We read the HMRC guidance (RFIG41000 Residence and FIG Regime Manual), the Autumn Budget 2024 legislation, and the Big 4 technical notes (Deloitte, KPMG, PwC, EY 2025 briefings), and cross-referenced with four UK private-client tax advisors between January 2026 and April 2026.

What ended on April 6, 2025

Until April 5, 2025, a UK-resident individual who was not UK-domiciled could claim the remittance basis. Under this, foreign income and gains were only taxed in the UK if brought (“remitted”) into the country. Keep the money offshore, and the UK didn't tax it — potentially for the first 15 years of UK tax residence, after which deemed domicile rules kicked in.

The remittance basis came with a charge: a flat annual fee of £30,000 after 7 of 9 tax years of UK residence, rising to £60,000 after 12 of 14 years. But for high earners with significant offshore income, the fee was trivial relative to the tax sheltered. This was the core of London's appeal for globally mobile HNWIs for a generation.

On April 6, 2025 — the first day of tax year 2025/26 — the remittance basis ceased to exist. Any foreign income or gains arising on or after that date are taxable in the UK on the worldwide-income basis, regardless of where the income sits or whether it's brought to the UK.

The new 4-year FIG regime — who qualifies

The FIG regime provides a complete exemption from UK tax on foreign income and gains for a time-limited 4-year window, but it's available only to people with at least 10 consecutive UK-non-resident tax years immediately before they become UK resident.

The specific eligibility test in RFIG41000:

1. 10 consecutive tax years of non-UK residence immediately preceding the first UK-resident tax year for which FIG is claimed. (Residence is determined under the Statutory Residence Test.)
2. The 4-year clock starts in the first UK tax year of residence. It runs for 4 consecutive UK tax years, used or not.
3. The claim is made annually in a Self-Assessment return, by January 31 of the second tax year after the relevant year. (So for 2025/26, the FIG claim deadline is January 31, 2028.)
4. Claiming FIG costs the personal allowance (£12,570 of tax-free income) and the annual CGT allowance (£3,000) for that year. Running the math is essential — FIG isn't automatically better.

Critically, FIG exempts foreign income and gains regardless of whether they're remitted. This is the single operational improvement over the old remittance basis: under FIG, you can bring foreign income and gains into the UK during those 4 years without triggering UK tax. That removes the legal and administrative burden of “clean capital” segregation that dominated non-dom planning for two decades.

After the 4 years expire: full worldwide taxation. Foreign income taxed at UK rates (up to 45% additional rate plus 8% for the 2025/26 savings rate band). Foreign gains taxed at UK CGT rates (24% from October 2024, increased from 20% for higher/additional-rate taxpayers). No renewable. No extension mechanism. The 4-year window is all there is.

Transitional rules for people already in the UK

If you were UK tax resident on April 6, 2025 but had been resident for fewer than 4 tax years (following at least 10 consecutive years of non-residence), you can use FIG for the remaining years of your 4-year window.

Examples based on Autumn Budget 2024 transitional guidance:

• Non-resident until 2023/24, became UK resident 2024/25. On April 6, 2025 you're in year 2 of UK residence. You can claim FIG for 2025/26, 2026/27, and 2027/28 (years 2–4).
• Non-resident until 2020/21, became UK resident 2021/22. On April 6, 2025 you're in year 5 of UK residence. FIG is not available — your 4-year window would have been 2021/22–2024/25, which ended before the regime started.
• Non-resident until 2024/25, became UK resident 2025/26. You get the full 4-year window: 2025/26 through 2028/29.

For anyone who had been in the UK for 5+ tax years on April 6, 2025 (the prior long-term non-doms), FIG is unavailable. The transitional softeners for this population are the Temporary Repatriation Facility (TRF) and the Capital Gains Tax rebasing option.

The Temporary Repatriation Facility (TRF)

Former remittance-basis users can designate previously sheltered foreign income and gains (that arose before April 6, 2025) and bring them into the UK at a reduced rate: 12% in 2025/26 and 2026/27, 15% in 2027/28. After April 5, 2028, the TRF closes permanently.

To put this in context: those same funds, if remitted after TRF closes, would be taxed at up to 45% (income) or 24% (gains). The TRF is effectively a discount of 60–73% for bringing pre-April-2025 offshore money into the UK in the next two tax years.

What's eligible:

• Foreign income and gains that arose before April 6, 2025 and that were sheltered under the remittance basis (not taxed because not remitted)
• Amounts held in offshore accounts, trusts, or invested in offshore assets prior to April 6, 2025
• Distributions from offshore trusts, where the underlying income is pre-April-2025 FIG (subject to the anti-avoidance rules introduced in Finance Act 2025)

What's not eligible:

• Foreign income or gains arising on or after April 6, 2025 (these are fully taxable under the regime that applies to the individual — FIG exemption or full UK residence)
• Funds that were never FIG under the remittance basis (UK-source income, previously-remitted amounts)
• Tainted amounts under certain anti-avoidance rules (check with a qualified advisor for specifics)

The mechanical process requires a designation election on a Self-Assessment return. Once designated, the funds are treated as fully taxed and can be remitted to the UK without further charge. The designation is irrevocable.

Practical TRF math for an illustrative non-dom:

• Former non-dom has £2M of pre-April-2025 offshore income sheltered under remittance basis.
• 2025/26 or 2026/27 designation:£2M × 12% = £240,000 tax. Remaining £1.76M is cleanly onshore.
• 2027/28 designation:£2M × 15% = £300,000 tax.
• No designation, remit later:£2M × up to 45% = up to £900,000 tax (income) or up to 24% = £480,000 (gains).

The TRF window closing April 5, 2028 is the most specific time-pressure moment in UK HNWI tax planning for 2026. Every private-client advisor we spoke with is running TRF-vs-don't projections for applicable clients now.

Capital Gains Tax rebasing to April 5, 2017

Non-doms who claimed the remittance basis in the 2017/18 tax year or later can elect to rebase foreign assets to their value on April 5, 2017. This means gains accruing between acquisition and April 5, 2017 are permanently excluded from UK CGT; only the gain from April 5, 2017 to disposal is taxable.

This is particularly valuable for equity holdings that went up materially from pre-2017 cost basis (e.g., US tech stocks, pre-2017 crypto positions) but are now sitting on substantial paper gains.

Eligibility narrow-points to confirm with an advisor:

• The asset must be foreign (not UK-situs)
• The asset must have been owned continuously since before April 5, 2017
• The individual must have claimed the remittance basis in 2017/18 or later
• Election is made on the CGT disposal; defaults apply if not elected

For a non-dom sitting on £5M of US-equity gains where £3M accrued before April 2017, rebasing saves £3M × 24% = £720,000 in CGTon disposal.

Inheritance Tax — the quieter but bigger reform

Effective April 6, 2025, Inheritance Tax moved from domicile-based to residence-based. This is arguably the most consequential piece of the April 2025 package for long-term UK residents who had been relying on non-UK-domicile status to shield offshore assets from UK IHT.

The new rules:

• Long-term UK residence test:An individual who has been UK tax resident for at least 10 of the preceding 20 tax years is a “long-term UK resident” and is subject to UK IHT on their worldwide assets.
• 10-year tail: Long-term residents who leave the UK remain subject to UK IHT on worldwide assets for up to 10 years after departure (with a scaling taper for those with between 10 and 20 years of UK residence). For someone with 20+ years of UK residence, the full 10-year tail applies.
• Pre-April 2025 planning voided: Excluded Property Trusts settled by non-UK-domiciled individuals before April 6, 2025 retain some IHT protection for non-UK assets that were transferred before that date, but the specific rules are complex and require individual advice.
• IHT rate unchanged:40% on assets above the £325,000 nil-rate band (plus £175,000 residence nil-rate band if applicable).

The 10-year tail is what's driving much of the HNWI departure pattern: leaving the UK in 2026 after 20 years means your worldwide estate is exposed to UK IHT until 2036. For someone with a £50M offshore estate, that's £20M of potential IHT exposure that doesn't extinguish until they've been gone a decade.

Where UK non-doms are actually going

The Henley Private Wealth Migration Report projected a net outflow of ~16,500 millionaires from the UK in 2025. The number has been methodologically challenged (Tax Justice Network and the Tax Policy Associates have noted the report is based on LinkedIn self-reporting and proprietary data with opaque methodology), but the directional trend is confirmed by multiple independent sources including HMRC's own non-dom reporting, and by private-client advisors across London's top law and accounting firms.

The destinations, ranked by volume of UK non-dom departures based on Henley + private-client advisor testimony:

1. UAE (Dubai, Abu Dhabi)

The default choice for liquid HNWIs. 0% personal income tax, 0% capital gains, 0% inheritance, 10-year Golden Visa, world-class private banking, English-speaking business-and-school ecosystem. The UAE Golden Visa has become the single most common visa path for departing UK non-doms per private-client advisors we spoke with. See our UAE visa complete guide and UAE country profile.

2. Italy — €200,000 flat-tax regime

The closest spiritual successor to the UK non-dom regime.Italy's HNWI flat-tax regime charges €200,000/year (raised from €100,000 in 2024) on worldwide non-Italian income and gains for up to 15 years. For someone with €5M+ of annual offshore income, €200K is trivial. Italy has been the single largest EU destination for departing UK non-doms per advisor testimony. See our Italy investor visa, moving to Italy guide, and Italy country profile.

3. Switzerland — lump-sum (forfait) taxation

The most discreet option.Swiss lump-sum taxation (forfait) is a negotiated per-canton tax based on lifestyle expenditure rather than worldwide income. Average annual tax is CHF 150K–500K depending on canton (Vaud, Geneva, Zug, Graubünden are most common). Not renewable in certain cantons but effectively permanent. Zero-noise lifestyle; high barrier to entry (must not be Swiss citizen, must not work in Switzerland, must prove self-sufficiency). See our Switzerland lump-sum taxation guide.

4. Monaco — residency with 0% personal tax

The classic.0% personal income tax, 0% wealth tax, 0% CGT for non-French nationals (French nationals are treated as French residents). Residency requires evidence of sufficient means (informally €500K+ in Monaco bank deposits, though requirements vary) and rental of Monaco property. €10K-20K/month minimum rent for a credible lifestyle.

5. Portugal — IFICI (narrower post-NHR)

The lifestyle option for eligible professionals.Portugal's old Non-Habitual Resident (NHR) regime was abolished in 2024. The replacement, IFICI (Tax Incentive for Scientific Research and Innovation), is narrower and employment- or qualification-linked. Not a direct non-dom replacement for most HNWIs, but still attractive for tech founders, researchers, and senior R&D staff. See our Portugal IFICI guide.

6. Malta — Global Residence Programme

The EU-adjacent low-tax option.Malta's GRP charges a flat 15% on foreign income remitted, with a minimum annual tax of €15,000. Non-EU-source income not remitted is untaxed. See our Malta MPRP guide.

7. Greece — non-dom regime

The Mediterranean 15-year HNWI play.Greece's €100,000 annual flat tax on foreign income for up to 15 years is a cheaper cousin of Italy's regime — half the cost, same structural benefit. Pairs with Greece's golden visa for residency.

Not in the top tier: Singapore, Jersey, Guernsey, Ireland

Singapore is highly discussed but APAC geography eliminates many UK-centric families. Jersey and Guernsey have long been tax havens but they're British Crown Dependencies with tightening substance requirements. Ireland's non-dom regime still exists but is politically unstable (reform rumblings since 2024).

The decision matrix: stay, FIG out, or leave

Based on our advisor interviews, the decision framework for someone currently in the UK:

The 2026-2028 action plan

If you're affected by any of the above, the specific calendar items that matter between now and April 2028:

Before April 5, 2027 (End of TRF Year 2 at 12%)

• Quantify pre-April-2025 offshore FIG balances with your accountant. This requires reviewing offshore account statements, investment platform records, and trust distributions going back 10–15 years.
• Model TRF vs. future remittance scenarios at both 12% and 15% rates. For most HNWIs with sheltered amounts > £1M, TRF makes sense.
• Designate TRF amounts via 2025/26 Self-Assessment by January 31, 2027.

Before April 5, 2028 (TRF closes permanently)

• Final opportunity at 15% rate. After this date, remittance is at full UK tax rates (up to 45% income, 24% gains).
• Complete any CGT rebasing elections on disposals before designation closes.
• Finalize IHT structuring decisions — long-term-resident status is locked-in once 10 years of UK residence is established.

For those planning to leave

• Model the 10-year IHT tail honestly. Leaving in 2026 after 20 years in the UK means worldwide IHT exposure until 2036.
• Confirm departure under the Statutory Residence Test. The “ties” framework makes ambiguous departures easy to challenge.
• Consider the destination's tax year alignment (UK April 6 – April 5 vs destination's fiscal year). This affects when FIG applies, when domicile splits, and the optimal departure timing.
• Exit tax implications: the UK doesn't have a general exit tax on leaving, but certain asset disposals may be accelerated or structured to optimize UK-vs-destination tax.

What the FIG regime means for incoming arrivals

If you're considering moving TO the UK in 2026 (as opposed to leaving), the FIG regime creates a specific 4-year window that you should plan around carefully:

• Year 1 of residence: FIG claim + exemption of all foreign income and gains. Free movement of offshore funds to the UK during this window without UK tax.
• Years 2–4: Continue FIG claims; begin transitioning to worldwide-income basis (restructure offshore income sources, consider corporatization of investment income in structures).
• Year 5 and beyond: Full UK worldwide taxation; at this point either your income is UK-legitimate-cost-aware or you should plan your departure before the 10-year IHT threshold.

For tech entrepreneurs, finance executives, and senior specialists considering UK roles: the 4-year window is long enough for a productive career cycle at a UK firm (and the Brexit-era Skilled Worker visa paths still provide the immigration piece). But it's not a long-term residence strategy for anyone whose ongoing income sources are predominantly offshore.

How this compares to alternative low-tax EU regimes

For someone leaving the UK, the comparison matters:

See our best low-tax countries for expats 2026 for a deeper side-by-side and worked examples at different income levels.

What the reform didn't change

For context, a few things that stayed the same:

• UK-source income remains UK-taxablefor everyone UK tax resident. UK salary, UK dividends, UK rental income — all taxed at UK rates regardless of FIG status.
• Statutory Residence Test rules unchanged.The day-count and ties framework continues to govern UK-tax-resident determination.
• UK resident companies taxed on worldwide profits.Corporate tax rules weren't part of this reform.
• Treaty reliefs continue to apply. UK double-tax treaties with ~130 countries remain operative; FIG interacts with treaty positions in complex ways that require case-by-case advice.

Related guides

• Best low-tax countries for expats 2026 — 8-regime comparison
• Complete guide to moving to the UK — for inbound arrivals
• Best countries to move to from the UK — general relocation guide
• UAE Golden Visa complete guide — #1 destination
• Italy investor visa 2026 — €200K flat tax
• Switzerland lump-sum taxation
• Portugal IFICI guide

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