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The End of Non-Dom Status: What the New FIG Regime Means for Expats

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The UK tax landscape is undergoing one of its most significant shifts in recent history: the end of the non-dom regime and the introduction of the Foreign Income and Gains (FIG) regime. What do these changes mean for globally mobile individuals.

What's Changing?

From April 6, 2025, the longstanding UK non-domicile tax status will be abolished. In its place, the UK government is introducing a new FIG regime designed to offer temporary relief for newcomers, while tightening tax obligations for long-term residents.

Who Will the FIG Regime Benefit?

The FIG regime allows qualifying individuals, those who have been non-resident in the UK for at least 10 of the previous 12 tax years to exclude overseas income and gains from UK tax for four tax years after arrival. However, this is a one-time opportunity. Once the four years are up, full UK tax exposure resumes.

That means:

No cherry-picking which assets to bring in.
No indefinite remittance basis.
No creative 'I’m-not-really-resident' arguments.

The tax clock starts ticking from the day you become UK tax resident, even if you only arrive part-way through the tax year.

Temporary Repatriation Facility (TRF)

For those who previously benefited from the remittance basis, a transitional 12% tax rate will apply to overseas income and gains brought into the UK during 2025–26 and 2026–27. After that, standard tax rates will apply.

This 'stick or twist' scenario creates complex planning challenges: Do you remit now and pay 12%, or wait and possibly pay more later?

A Shift with Global Consequences

The UK appears to be pivoting away from long-term incentive structures in favour of short-term newcomer relief. But with countries like Italy, Greece, and Spain offering increasingly attractive tax schemes to expats, this may push wealth and talent abroad.