Everything About UK Non‑Dom Tax Changes in April 2026

What changed in non-dom tax from April 2025

From 6 April 2025, the long‑running remittance basis ended. In practical terms, the UK no longer taxes most “non‑dom” individuals on foreign income and gains only when money is brought into the UK. Instead, UK tax residence is now the main driver, with a new relief aimed at genuinely new arrivals. 

What that means day‑to‑day: from 6 April 2025, UK residents are generally taxed on worldwide income and gains as they arise, unless they qualify for and claim the new Foreign Income and Gains regime for new/returning residents. 

Topic	Up to 5 April 2025 (remittance basis era)	From 6 April 2025 (current rules)
Main “gateway”	Domicile + a remittance basis claim (and related rules)	Residence‑led: worldwide taxation on the arising basis, unless it is in the new regime
Foreign income & gains (newly arising)	Often taxed only if remitted (subject to conditions)	Taxed as they arise for most UK residents; relief available for qualifying new residents
Bringing foreign funds to the UK	Could trigger UK tax if the funds were untaxed FIG	For eligible FIG under the new regime, remitting does not create a UK charge; for historic FIG, old remittance concepts still matter

The Foreign Income and Gains regime for new residents

The cornerstone of the reform is a four‑tax‑year “Foreign Income and Gains” relief for people who are genuinely new (or returning) to the UK tax net.

Who can claim foreign income and gains relief

You can claim foreign income tax and gains relief if you are a UK tax resident under the Statutory Residence Test and are still within your first four tax years of UK residence after at least ten consecutive tax years of non-UK residence. 

A key point many people miss is that if your UK residence started before 6 April 2025, you may still be able to use the regime from 2025/26 onwards for whatever part of your four‑year window remains (there is no “reset” unless you have a further ten‑year non‑resident period). 

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What relief you get

If you make a valid claim, you do not pay UK tax on eligible foreign income and foreign gains for the sources you claim, and remitting those relieved amounts to the UK does not create a tax charge. 

Eligible foreign income includes, for example, overseas trade profits, overseas property business profits, non‑UK dividends and foreign interest. 

The trade-offs: what you give up

Claiming comes with a cost. If you claim under the regime, you lose key UK allowances for that tax year, including income tax and capital gains tax allowances and certain marriage‑related allowances. 

Also, even where relief applies, foreign income and gains typically still need to be reported (the old “leave it offshore and don’t report it” mindset is no longer a safe default). 

Transitional rules for former remittance basis users

The reform did not wipe the slate clean for earlier years. Historic offshore funds still need careful handling, and this is where many accidental tax bills arise.

Historic foreign income and gains are still “historic”: 

Where someone used the remittance basis before 2025/26, the remittance basis can still apply to income and gains that arose in those earlier tax years. In simple terms, those historic amounts can still become taxable if and when they are remitted, unless you use a specific transitional facility. 

The Temporary Repatriation Facility:

The main transition tool is the Temporary Repatriation Facility. It runs for a fixed three‑tax‑year period and is designed to let former remittance basis users bring pre‑6 April 2025 offshore income and gains to the UK at a flat, reduced charge by designating amounts and paying the TRF charge. 

TRF designation year	Flat TRF charge on designated “qualifying overseas capital”
2025/26 or 2026/27	12%
2027/28	15%

Two practical points matter in real life:

• You do not have to remit the designated amount during the TRF window to benefit from the reduced rate; designation can be done and funds brought over later without further UK tax on that designated amount. 
• If you remit an amount in a tax year but fail to designate it in that same year’s return, you can be exposed to the normal remittance taxation (designating later will not “fix” a prior remittance). 

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CGT rebasing for certain foreign assets:

A separate transitional relief allows some former remittance basis users to rebase certain personally held foreign assets to their market value at 5 April 2017, so that only post‑rebasing growth is taken into account for UK capital gains tax on a later disposal. The government’s published design includes conditions such as holding the asset at 5 April 2017 and disposing of it on or after 6 April 2025. 

Payroll support for mobile employees:

For globally mobile employees, employers can notify HM Revenue & Customs that they will operate PAYE on only the proportion of earnings related to UK duties (the mechanism previously associated with “section 690”). The current guidance also covers split‑year cases and employees eligible for Overseas Workday Relief. 

Inheritance tax becomes residence-based

Inheritance tax is now aligned with residence history, not domicile labels.

From 6 April 2025, the domicile and deemed‑domicile framework for bringing non‑UK assets into inheritance tax was replaced by a long‑term UK resident test. If you are long‑term resident, your overseas assets can fall within UK inheritance tax on death or on certain lifetime transfers. 

Who is a “long-term resident”

You are generally a long‑term resident if you have been UK tax resident for at least ten out of the prior twenty tax years. There is also a rule set that can treat you as long‑term resident after ten consecutive years. 

The “tail” after leaving the UK

Leaving the UK does not necessarily end exposure immediately. The inheritance tax manual sets out a tail that can run from three up to ten tax years, depending on how many years of UK residence you have in the look‑back period. 

Trusts are directly in scope

The long‑term residence framework also affects trusts. The official guidance states that inheritance tax can be charged on overseas assets in a trust you set up or added to, with specific conditions and exceptions depending on when assets were settled and their location at key dates. 

How We Help Clients Navigate UK Non-Dom Tax Changes

At Apex Accountants, we focus on the practical work clients need to stay compliant and avoid avoidable tax costs under the post‑April 2025 rules.

We typically help with:

• Residence and eligibility reviews to confirm whether the Foreign Income and Gains regime is available and which claims are worth making.
• TRF planning and designation support, including fund tracing, mixed-fund cleanup strategy, and ensuring designations align with remittance timelines.
• CGT modelling and rebasing support, including “before and after” disposal scenarios and valuation requirements.
• Inheritance tax exposure mapping, particularly around long‑term resident status, tail periods, and trust interaction.
• Employer and payroll guidance for globally mobile employees, including PAYE proportion notifications and split‑year considerations.

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Conclusion

The abolition of the remittance basis from 6 April 2025 has shifted the UK to a residence‑led approach: worldwide taxation is now the default for UK residents, with a tightly defined new‑arrival relief, specific transitional tools for historic offshore funds, and a major reset for inheritance tax based on long‑term residence. 

FAQs

1. Can I still use the remittance basis?

Not for new income and gains from 6 April 2025. However, the remittance concept remains relevant for pre‑6 April 2025 foreign income and gains that arose while you were on the remittance basis. 

2. Do I get four years completely tax‑free in the UK?

You can receive 100% UK relief on eligible foreign income and gains during your qualifying period, but only if you qualify and make a claim. You may also lose UK allowances in the year(s) you claim. 

3. If I claim the new regime, do I still have to report foreign income and gains?

In most cases, yes. The reporting position has tightened, and many more UK residents now need to report foreign income and gains even when relief applies. 

4. Can I bring historic offshore income to the UK tax‑free during the transition window?

No “amnesty” applies. The transition tool is the TRF, which offers a reduced flat charge (not a zero rate) if you designate correctly. 

5. What happens after the qualifying period ends?

Once your qualifying period ends, your default position is the normal UK arising‑basis taxation on worldwide income and gains. 

6. When does inheritance tax start applying to overseas assets?

From 6 April 2025, overseas assets can be within UK inheritance tax if you meet the long‑term resident test, with a tail that can continue after departure.