If you’re a non-dom or internationally mobile individual, the UK’s tax landscape has undergone a significant shift. As of 6 April 2025, the domicile-based system and remittance basis has gone. In its place, a new residence-based system is now in effect.
There’s still plenty of confusion around what this actually means — especially for those with offshore assets, trusts, or long-term ties to the UK.
Some key changes:
- The remittance basis is out, and a new four-year Foreign Income and Gains (FIG) regime is in for qualifying individuals.
- There’s a Temporary Repatriation Facility offering a reduced tax rate to bring historic foreign income and gains into the UK where conditions are met.
- Offshore trusts are no longer protected in the same way.
- Inheritance Tax is now tied to years of UK residence, not domicile.
- Existing Excluded Property Trusts may still benefit from favourable treatment, but only in certain conditions.
These changes affect income tax, capital gains tax and inheritance tax planning. If you have previously relied on the non-dom rules in any way, now is the time to review your position and take advice if you have not already done so.
We’ve put together a straightforward fact sheet that breaks down the key areas and action points.