Reforms to taxation of non-doms from April 2025

From 6 April 2025, the remittance basis of taxation will be scrapped in favour of a residence-based system. A new 4-year Foreign Income and Gains regime offers tax relief for new arrivals, while transitional measures aim to ease the shift. Here’s what’s changing.

Effective from 6 April 2025, the remittance basis of taxation for non-UK domiciled individuals will be replaced by a simplified, residence-based tax regime.

Additionally, the government will introduce a 4-year Foreign Income and Gains (FIG) regime. Under this regime, individuals newly arriving in the UK who choose to participate will receive full relief (100%) on foreign income and gains during their first four years of UK tax residence, provided they have not been UK tax resident in any of the preceding 10 consecutive years.

As a transitional measure for Capital Gains Tax (CGT) purposes, individuals who have previously used the remittance basis will have the option to rebase personally held foreign assets to their value as of 5 April 2017, provided certain conditions are met.

Furthermore, Overseas Workday Relief will be extended to cover a 4-year period, in line with the new 4-year FIG regime. This change will eliminate the need for individuals using this relief to keep their employment income offshore. From 6 April 2025, the maximum amount of Overseas Workday Relief that can be claimed annually will be the lesser of £300,000 or 30% of the individual's net employment income.

A new Temporary Repatriation Facility (TRF) will also be introduced from April 2025 for a 3-year period. This facility will allow individuals who have previously been taxed on the remittance basis to designate and remit foreign income and gains that arose prior to the reform, at a reduced rate. This includes foreign income and gains held within trust structures that have not been attributed. The TRF will offer a rate of 12% for the first 2 years, and 15% in the final year of its operation.