UK FIG regime: how the 4-year rule replaced non-dom status

What this covers

The 4-year FIG regime is a UK relief, set out in Finance Act 2025, that lets a qualifying new UK resident claim relief from UK tax on chosen foreign income and foreign gains for each of up to 4 tax years. It replaced the remittance basis, which until 5 April 2025 let some UK residents with a domicile outside the UK pay UK tax only on foreign income and gains brought into the UK. The same reform moved inheritance tax from a domicile test to a long-term residence test and created a temporary facility for bringing older foreign income and gains to the UK.

Understand what ended on 6 April 2025

HMRC's guidance says that on 6 April 2025 the foreign income and gains regime replaced the remittance basis. Before that date, UK residents whose permanent home, or domicile, was outside the UK could claim to pay UK tax only on the foreign income and gains they brought into the UK. GOV.UK now describes those rules in the past tense.

The legal change is in Part 2 of Finance Act 2025, titled Replacement of special rules relating to domicile. It covers the new rules for people becoming UK resident, the temporary repatriation facility and the move to a long-term residence test for inheritance tax.

The change does not wipe out the past. HMRC says foreign income or gains that arose in a year when the remittance basis was claimed stay taxable when they are brought to the UK, and that this treatment continues for all previous remittance basis users after 6 April 2025.

Check the 10-year and 4-year conditions

HMRC describes a qualifying resident as someone who is UK tax resident under the Statutory Residence Test and is within their first 4 years of UK tax residence after at least 10 consecutive tax years of non-UK tax residence. Residence for each year is decided by the Statutory Residence Test, so the day counts and ties for every one of those years matter.

The 4 years run from the start of UK residence and are consecutive. HMRC says unused years cannot be carried forward. If a person becomes non-UK resident for a year inside the 4-year window, they cannot claim for that year but can claim for the remaining qualifying years after returning.

People who arrived before the change can use what is left of their window. HMRC says that if the 4-year period began before 6 April 2025, a claim can be made from 2025 to 2026 up to the last year of that period. Its example of residence starting on 6 May 2022 leaves only 2025 to 2026 available.

Know what a FIG claim covers and what it costs

HMRC lists qualifying foreign income as profits of a trade carried on wholly outside the UK, profits of an overseas property business, dividends from non-UK resident companies and interest such as interest on a foreign bank account. The HS266 helpsheet adds foreign pension income and qualifying foreign gains, with exclusions for disqualified income. You choose which foreign income and gains to claim on, and you do not have to claim on all of them.

Foreign employment income is not part of a FIG claim. HMRC points employees to Overseas Workday Relief, which is a separate election. Its manual says relief from 6 April 2025 is limited each qualifying year to the lower of 30% of the relevant qualifying employment income or £300,000, and that the earnings can be paid into a UK or overseas account without affecting the relief.

A claim has a price. HS266 says a claim year loses the personal allowance, the capital gains tax annual exempt amount, blind person's allowance, the married couple's tax reductions and the transferable marriage allowance, and relief for some life insurance payments. Foreign losses cannot be claimed in a claim year. HMRC also says claimed foreign income still counts toward adjusted net income, which can affect childcare support and the High Income Child Benefit Charge.

Relieved income and gains do not have to stay offshore. HS266 says there is no UK tax liability if you choose to bring them to the UK.

Make the claim on the Self Assessment return

HMRC says the claim is made on the Self Assessment tax return, so a person who is not registered must register first. HS266 describes ticking box 28 on the SA109 pages for foreign income and box 29 for foreign gains, with each source still reported on the relevant pages such as SA106 and SA108.

The claim is not automatic and is made for each tax year. HS266 gives the deadline as the anniversary of 31 January following the end of the tax year. For 2025 to 2026 that is 31 January 2028.

• Confirm UK residence for each year under the Statutory Residence Test, including any split year.
• Confirm at least 10 consecutive tax years of non-UK residence before the first UK year.
• List each foreign income source and gain, and decide which ones to claim on.
• Weigh the allowances lost in that year against the relief.
• Keep records of the foreign amounts declared, since the claim is for the amounts on the return.

Look at the Temporary Repatriation Facility for older foreign income

The Temporary Repatriation Facility (TRF) is for people who used the remittance basis before. HS264 says you must be UK resident in the tax year of designation and must have previously used the remittance basis. It lets you designate qualifying overseas capital and pay a flat charge on it instead of tax at normal rates when it is brought to the UK.

HMRC gives three tax years and two rates: 12% for 2025 to 2026 and 2026 to 2027, and 15% for 2027 to 2028. Qualifying overseas capital includes foreign income and gains that arose before 6 April 2025, funds of uncertain origin, some capital payments from non-UK trusts matched to pre-6 April 2025 income or gains, and overseas assets such as property or investments.

Designation is made on the SA109 pages. HS264 says the charge is a charge on capital, not a tax on income or gains, that no foreign tax credit can be set against it, and that you do not have to bring the money to the UK during the TRF period to use the rate. Designated amounts can later be brought in without further UK tax. Amounts not designated stay taxable at the usual rates when remitted, so records of mixed funds matter.

Check the long-term residence test for inheritance tax

From 6 April 2025, HMRC says inheritance tax on overseas assets depends on long-term UK residence rather than domicile. A person is a long-term UK resident in a tax year if they were UK tax resident for the previous 10 consecutive years or for at least 10 of the previous 20 years. Long-term residents are within inheritance tax on overseas assets they own outright, on transfers and on death.

Long-term residence can follow you after you leave. HMRC says it can continue for up to 10 tax years after departure, and less for people who did not live in the UK for all of the previous 20 years. Its examples: 10 to 13 years in the UK gives 3 years after leaving, 14 years gives 4, and 15 years gives 5.

HMRC sets out transitional rules for people who were not UK domiciled or deemed domiciled on 30 October 2024 and for people who were deemed domiciled on that date. These turn on residence in the 2025 to 2026 tax year and on not returning to the UK. Trust assets have their own rules. Read the HMRC page and take the facts to an adviser rather than relying on a summary.

Note the transitional points HMRC lists

HMRC's 2024 policy paper, published before the law passed, says current and past remittance basis users can rebase foreign assets held on 5 April 2017 to their value on that date when they dispose of them. Check the conditions in the current legislation and HMRC guidance before relying on it.

For Overseas Workday Relief, HMRC's manual says relief for some employees who became UK resident in 2022 to 2023, 2023 to 2024 or 2024 to 2025 and used the remittance basis is not subject to the financial limit for tax years ending before 6 April 2028. The manual also says earnings from remittance basis years must be paid offshore or they are taxable on receipt.

Leaving the UK raises separate questions about the year of departure, split-year treatment and what stays taxable. See leaving a country for tax and the United Kingdom country page.

Common misconceptions

Questions to take to a professional

1. Was I non-UK resident under the Statutory Residence Test for at least 10 consecutive tax years before my first UK year, and how is a split year treated?
2. Which of my foreign income sources and gains would a FIG claim cover, and which would be disqualified income?
3. How much would losing the personal allowance and the capital gains annual exempt amount cost in a claim year?
4. Does my work abroad qualify for Overseas Workday Relief, and how does the financial limit apply?
5. Do I hold foreign income or gains from remittance basis years that could be designated under the TRF, and what records show their origin?
6. When would I become, or stop being, a long-term UK resident for inheritance tax, and how are any trusts affected?

Questions people ask

Sources

• Check if you can claim the 4-year foreign income and gains regimeOfficial guidance
• HS266 Foreign income and gains (FIG) regime (2026)Official guidance
• HS264 Remittance of pre-6 April 2025 foreign income and gains, and the temporary repatriation facility (TRF)Official guidance
• Remittance basis changesOfficial guidance
• Inheritance Tax if you're a long-term UK residentOfficial guidance
• Reforming the taxation of non-UK domiciled individuals (HMRC policy paper, 30 October 2024)Official guidance
• EIM43600 Globally mobile employees: Overseas Workday Relief: financial limitOfficial guidance
• EIM43555 Globally mobile employees: Overseas Workday Relief: overviewOfficial guidance
• Tax on foreign income: 'Non-domiciled' residentsOfficial guidance
• RDR3: Statutory Residence Test (SRT) notesOfficial guidance
• Finance Act 2025, Part 2: Replacement of special rules relating to domicilePrimary law