Non-Dom Abolition April 2025 — FIG Regime Tax Impact Calculator

The non-domiciled tax status was abolished from 6 April 2025. This ended the ability to use the remittance basis of taxation, which allowed non-doms to pay UK tax only on UK income and gains, and on overseas income only when brought to the UK. From April 2025, a residence-based system applies for all UK residents.

The FIG regime replaces the non-dom remittance basis. New UK residents who have not been UK-resident in the previous 10 years can elect to pay no UK tax on foreign income and gains for their first 4 UK tax years of residence. After 4 years, full worldwide taxation applies — foreign income and gains are fully taxable in the UK.

The TRF is a transitional measure allowing former remittance-basis users to bring pre-April 2025 overseas income and gains to the UK at reduced tax rates: 12% in 2025/26, 15% in 2026/27, and 15% in 2027/28. This allows existing non-doms to clean up offshore funds at a reduced tax cost before they become fully taxable.

From April 2025, the IHT treatment of long-term UK residents changed fundamentally. Previously, non-doms were only liable for IHT on UK-sited assets. Under the new rules, individuals who have been UK-resident for 10 out of the last 20 years face IHT on worldwide assets. This is a major change for wealthy non-doms with significant offshore assets.

Yes. A transitional rebasing was available for certain non-dom individuals. The FIG regime includes a one-off rebasing election for individuals who were non-dom and used the remittance basis, allowing gains to be measured from 5 April 2017 (or acquisition cost if later) rather than original cost. This reduces the taxable gain on future disposals.

To qualify for the FIG 4-year exemption, you must not have been UK-resident in any of the 10 consecutive tax years immediately before your current period of UK residence. For example, someone who left the UK 10 years ago and returns in 2025/26 can qualify for the 4-year FIG exemption.

The Overseas Workday Relief (OWR) continues in modified form from April 2025 for the first 3 years of UK residence. It allows relief on employment income attributable to days worked outside the UK, but only for those who are also eligible for the FIG regime (i.e., first 4 years of residence following 10 years abroad).

Non-doms who were already UK-resident when the regime changed faced different treatment depending on their years of residence. Those with under 4 years of UK residence can potentially access the FIG regime. Those with 4-15 years face full worldwide taxation from April 2025. Those with 15+ years face the new IHT worldwide basis.

The changes apply from 6 April 2025 going forward. Pre-2025 remittance-basis funds are not automatically taxed — but if brought to the UK after April 2025, they may be taxable unless covered by the TRF window. The TRF specifically addresses this historical offshore income/gain accumulation.

UK residential property was already subject to UK CGT and IHT for non-doms (NRCGT from 2015, UK IHT on UK property via offshore structures closed). The April 2025 changes primarily affect overseas income, gains, and worldwide IHT exposure — the UK property position was already largely settled.

Yes significantly. Protected settlements (offshore trusts) previously sheltered from UK IHT and often from UK income/CGT through the remittance basis. From April 2025, the trust protections have been significantly reduced. The trust rules are extremely complex and fact-specific — trust structures established by non-doms urgently need professional review.

Some high-net-worth individuals have left the UK to avoid the increased tax burden from the abolition. For those remaining, the key steps are: (1) Consider TRF window, (2) Review offshore trust structures, (3) Plan for IHT exposure on worldwide assets, (4) Consider rebasing elections. Leaving the UK has its own exit tax implications that also need careful planning.