On 6 April 2025 the UK changed one of the best-known features of its international personal-tax system.
The old remittance-basis architecture for non-UK domiciled individuals was removed for current income and gains and replaced by a new regime based on recent tax-residence history: the four-year foreign income and gains regime, or FIG.
The practical shift was from domicile as the central gateway to a residence-history test.
Key takeaways
- From 6 April 2025 the remittance basis ceased to be available for current years and the new FIG regime became the relevant relief for qualifying new residents.
- FIG is not a new “non-dom status”: eligibility depends on being within the first four years of UK tax residence after at least ten consecutive years of non-UK tax residence.
- Pre-6 April 2025 foreign income and gains, transitional facilities and other taxes can still matter, so old and new regimes must be separated carefully.
What changed on 6 April 2025
HMRC’s current guidance states that the four-year FIG regime replaced the remittance basis on 6 April 2025.
A qualifying resident can claim relief on eligible foreign income and gains while within the relevant four-year window, provided the person satisfies the residence-history conditions.
The reform also changed the broader role of domicile in the tax system, including movement toward residence-based rules in areas that had historically depended on domicile.
For the archive, the decisive point is that the new regime should not be described as though it had always been known in its final form. It followed a period of announcements, policy changes and legislation before becoming effective.
Why it was a turning point
The non-dom/remittance-basis system had shaped UK planning for internationally mobile individuals for generations.
Its logic was distinctive. A UK resident who qualified for the remittance basis could, subject to the rules and consequences, have foreign income and gains treated differently depending on whether they were remitted to the UK.
The 2025 reform changed the organising principle.
Instead of asking primarily about domicile and remittance-basis status, new-arrival planning now asks when UK tax residence began and whether the individual had a sufficient prior period of non-UK residence.
That makes timing much more explicit.
What was misunderstood
The shorthand “the UK abolished non-dom” can create several errors.
First, it can imply that every historical consequence of the old system vanished on 6 April 2025. It did not. Pre-reform foreign income and gains can still matter when remitted, subject to transitional rules.
Second, it can imply that every person moving to the UK receives four tax-free years on foreign income and gains. They do not. Eligibility and claims have conditions.
Third, it can imply that FIG relief makes all UK taxes irrelevant. It does not. UK-source income, other tax rules, inheritance-tax exposure, employment rules and the treatment of structures can all require separate analysis.
The reform simplified one gateway and complicated the transition between regimes.
The replacement: four-year FIG
The four-year FIG regime is available to qualifying residents within their first four years of UK tax residence following at least ten consecutive tax years of non-UK tax residence.
If a person’s four-year period began before 6 April 2025, only the remaining qualifying years may be available.
Claims are made for eligible foreign income and gains, and making a claim has consequences including the loss of certain personal allowances.
The crucial point is that the relief is a time-limited residence-based regime, not a permanent personal status.
What happened to old foreign income and gains?
The abolition of the remittance basis did not erase amounts that arose under the old system.
HMRC guidance confirms that pre-6 April 2025 foreign income and gains can remain relevant when remitted after the reform.
Transitional rules, including the Temporary Repatriation Facility, were introduced to address parts of that legacy stock.
This creates a practical need to distinguish:
new FIG → pre-2025 unremitted amounts → transitional designations → ordinary arising-basis taxation.
Mixing those categories is a common source of error.
What changed since then?
By 2026 HMRC has a developed body of guidance for the FIG regime and transition.
The reform is therefore no longer a future policy question. Individuals are filing and planning within the new system.
This makes historical labels less useful. A person who was once called “non-dom” still needs a current analysis of residence history, foreign income, trusts, remittances and the specific tax year.
The strongest objection
A strong objection is that the new FIG regime can still be highly competitive for genuine new arrivals, so calling 2025 “the end of the non-dom era” can sound more dramatic than the economic reality.
That is fair.
The UK did not stop offering targeted relief for international arrivals. It changed the legal mechanism and narrowed the time horizon.
The turning point is therefore institutional, not a claim that the UK ceased to compete for internationally mobile people.
What it means for an international person
A current UK arrival analysis should begin with a timeline.
Questions include:
- in which tax year did UK residence begin;
- were the previous ten tax years non-UK resident;
- how many FIG years, if any, remain;
- what foreign income and gains are eligible;
- what pre-6 April 2025 unremitted amounts exist;
- whether transitional facilities are relevant;
- how trusts or companies interact with the individual; and
- how UK residence affects other taxes and reporting.
The old question “are you non-dom?” is no longer enough.
The modern question is: what is your residence history, what income exists, and which regime applies to each amount in each year?
Sources
- HMRC — Check if you can claim the 4-year FIG regime
- HMRC — Tax changes for non-UK domiciled individuals
- HMRC — Temporary Repatriation Facility and pre-6 April 2025 FIG
Disclaimer
This article is general historical and UK tax information, not tax or legal advice. FIG eligibility, transitional treatment, trusts and other UK taxes depend on individual facts and the relevant tax year. Current HMRC guidance and legislation should be reviewed before acting.
