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 |
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