For over two centuries, the United Kingdom’s “non-dom” regime was the bedrock of its appeal to the global elite. It was a system built on the complex, often elusive concept of domicile: a legal tie to a country that wasn’t necessarily where you lived, but where you ultimately considered “home.” But as of 6 April 2025, that era has officially ended, making way for the modern UK FIG regime.
In its place, we have seen the rollout of a modern, residence-based Foreign Income and Gains (FIG) regime. Now that we are well into 2026, the dust has settled, and the practical reality of this shift is clear: the UK has traded complexity for clarity. For international residents, entrepreneurs, and high-net-worth individuals, the message is louder than ever: the UK is open for business, and the rules of engagement are finally predictable.
At Del Canto Chambers, we have spent the last year navigating these changes with our clients. What we’re seeing is a regime that, in many ways, is more generous and far more flexible than the one it replaced.
A Cleaner, Simpler Welcome: The 4-Year Window
The standout feature of the new FIG regime is its radical simplicity. For years, the “remittance basis” required a dizzying array of segregated bank accounts and a constant fear of “tainting” funds. If you accidentally brought the wrong pound into the UK, you could trigger a massive tax bill.
That is now a thing of the past. Under the new rules, any individual who has been a non-UK resident for at least the ten preceding tax years can claim a full exemption from UK tax on their foreign income and gains for their first four years of UK residence.
What makes this particularly attractive is that during this four-year window, you can bring that money into the UK freely. Whether you want to buy a home in Chelsea, invest in a tech startup, or fund a philanthropic venture, you can do so without a second look from HMRC. The old “remittance basis charge” — which ranged from £30,000 to £90,000 per year depending on years of UK residence, just for the privilege of being a non-dom — has been scrapped.
Domicile is Dead, Residence is King
The shift from domicile to residence cannot be overstated. Domicile was a legal minefield. It was a “sticky” concept that could follow you across oceans and decades. The new FIG regime uses a bright-line, statutory residence test. You are either a resident or you aren’t.
This clarity allows for much better long-term planning. For the first time in modern memory, legal advisors can sit across from a client and explain their tax liability with absolute certainty. This “bright-line” approach reduces the need for expensive, protracted litigation over where a person’s “heart and soul” truly lies. It is a pragmatic move that reflects the reality of the 21st-century global citizen.
The Temporary Repatriation Facility (TRF): A Golden Opportunity within the UK FIG Regime
While the four-year window is fantastic for newcomers, the UK government also recognised that existing “non-doms” needed a way to transition into the new system without being penalised. This is where the Temporary Repatriation Facility (TRF) comes in, and it is arguably the most significant tax-planning opportunity provided by the UK FIG regime.
If you were a remittance-basis user before 6 April 2025, you likely have significant “untaxed” foreign income and gains sitting in offshore accounts. Under the TRF, you can “designate” pre-6 April 2025 foreign income and gains accumulated while on the remittance basis, and pay a concessional flat charge. Mixed funds and ordering rules still apply, and not all offshore assets will qualify without prior analysis.
For the 2025/26 and 2026/27 tax years, that rate is a remarkably low 12%. It is a central pillar of the UK FIG regime‘s transitional phase, allowing for a massive consolidation of wealth. Once you have paid this flat fee, those funds are “cleansed,” and you can bring them into the UK whenever you like with no further UK tax.
For many of our clients at Del Canto Chambers, this has allowed for a massive consolidation of wealth. It’s a chance to bring offshore assets “onshore” at a fraction of the cost that would have been required under the old rules.
Rebasing Assets: Protecting Your Gains
Another crucial tool in the transitional toolkit is the “rebasing” of qualifying foreign assets. For non-doms who previously claimed the remittance basis, the government has allowed foreign-sited assets to be rebased to their 5 April 2017 market value, provided the individual claimed the remittance basis in at least one tax year from 2017 onwards. UK-sited assets do not qualify.
This means that if you sell a foreign asset now, you are only taxed on the gain that has occurred since 2017, not since you originally acquired it. For long-held investments or family businesses, this can result in a substantial reduction in Capital Gains Tax. It’s another example of how the new regime has been designed with an eye toward fairness and practical transition.
A Word on Inheritance Tax
It is worth noting that the FIG regime does not alter the UK’s Inheritance Tax (IHT) position. From 6 April 2025, IHT applies on a residence-based test: individuals who have been UK resident for ten of the preceding twenty tax years will be subject to IHT on their worldwide assets. For high-net-worth clients with significant global estates, this remains a critical planning consideration that sits alongside, but entirely separate from, the FIG exemption.
International Mobility and the Global Context
The FIG regime doesn’t exist in a vacuum. In January 2026, HMRC provided much-needed confirmation that a FIG claim does not prejudice an individual’s treatment under double tax treaties. This was a vital piece of the puzzle for internationally mobile clients who may have tax obligations in multiple jurisdictions.
We often work with clients moving between the UK, Spain, Colombia, and the Middle East. For those considering a move between the UK and Spain, the FIG regime interacts directly with Spain’s Beckham Regime (Article 93 LIRPF), and understanding how both windows align is essential to avoid gaps in protection. Similarly, for clients with Colombian-source income or assets, the UK-Colombia Double Taxation Treaty — particularly its provisions on dividends and capital gains — requires careful mapping against the FIG exemption period to ensure treaty benefits are preserved. Whether you are looking at moving to Dubai or considering the tax implications of a Spanish Holding Company (ETVE), the UK’s new regime fits much more neatly into a global tax strategy than the old non-dom rules ever did.
Why the UK? The Opportunity Ahead under the UK FIG Regime
You might ask why the UK chose this moment to simplify its tax code. The answer is competition. Globally mobile entrepreneurs and family offices have more choices than ever. By offering four tax-free years through the UK FIG regime, the UK is effectively providing a “landing strip” for talent.
It gives a family time to settle, find schools, and establish roots without the immediate pressure of worldwide taxation. It gives an entrepreneur time to scale a business before the tax man comes knocking on their global portfolio.
This is an invitation. The UK is betting that once people experience the benefits of living and working in London, Manchester, or Edinburgh, they will choose to stay long-term, even after the initial four-year window expires. The UK FIG regime is the cornerstone of this strategy, proving that the country remains a premier destination for global wealth.
UK FIG Regime Practical Steps: Don’t Wait Until the Deadline
While the UK FIG regime regime is simpler, it is not “automatic.” It must be claimed annually via self-assessment, and doing so means forgoing the personal allowance (£12,570) and the CGT annual exempt amount for that year — a trade-off that requires careful modelling for each individual. Furthermore, the TRF 12% window is time-limited. If you miss the 2026/27 deadline, the cost of bringing your money home goes up.
At Del Canto Chambers, our international tax experts recommend a three-step approach:
- Audit Your Assets: Identify exactly what foreign income and gains you have and where they are held.
- Model the TRF: Calculate whether designating funds at 12% makes sense for your long-term UK investment goals.
- Review Your Domicile History: Even though the system is residence-based, understanding your past domicile status is essential for correctly applying the transitional rebasing rules.
Conclusion: A Redesigned Door
The death of the non-dom regime was met with a lot of anxiety, but the reality of the FIG regime is far more positive than many predicted. The UK has essentially redesigned its front door. It is now wider, more transparent, and significantly easier to walk through.
Whether you are a long-time resident looking to simplify your affairs or a prospective resident looking for a new home base, the current landscape offers unprecedented opportunities for tax efficiency and financial freedom.
If you have questions about how these changes affect your specific situation, or if you want to explore how the FIG regime interacts with your international assets, our team is here to help. You can reach out to our direct access barristers or contact us via email for a confidential consultation.
