PWM International

Foreign income
and gains regime

From 6 April 2025, the UK government replaced the historical regime for resident non-domiciled (RND) individuals with the foreign income and gains (FIG) regime, which is based on residence, rather than domicile.

If you’ve already arrived in the UK or are planning to, or if you were previously considered non-domicile, it’s important that you understand how the new rules will impact you and any existing financial planning you have in place. Our experienced International specialists can advise and support you to ensure your finances are optimised for the new regime. 

An introduction to the FIG regime An introduction to statutory residence basis

Changes to tax on foreign income or gains

If you are a new UK resident, the new regime means you will not pay tax on foreign income and gains for four years. This is a shorter period than the previous remittance basis regime, but there is a benefit – you can then bring the funds into the UK without any additional UK tax being applied.  

If you’ve historically used the remittance basis regime, you also have the potential to use a temporary repatriation facility (TRF). The TRF allows for historic untaxed income or gains to be “designated”, meaning they have a fixed rate of tax applied. As a result, they are cleared for UK remittance without additional UK taxation. 

Changes to Inheritance Tax (IHT)

How Inheritance Tax (IHT) is applied also changes under the new regime. Now that residence is the important factor, rather than domicile, it should make it clearer whether you are or aren’t subject to UK IHT on a global basis.  

Nonetheless, if you’re a temporary UK resident, you’ll want to pay extra attention to your UK residency status. Global UK IHT remains in place for up to 10 years after leaving the UK, so it could have a lasting impact long after you leave. 

For more information on the new rules and how they could impact you, take a look at our  Introduction to foreign income and gains (FIG) regime guide. 

How we can help 

When you work with us, you can be confident that your financial advice is backed by extensive experience with complex, cross border situations as well as in-depth knowledge of the UK tax regime.  

Our International team has worked with the concepts of domicile, remittance, and mixed funds on behalf of our clients for years, and our participation in HMRC’s consultations on the new regime means we really understand the detail. We’ll use this experience alongside our robust methodology and vast professional network to advise and support you to optimise your financial affairs no matter your residency status. 

Nathan Prior

For further information

To find out more about how we can help you with no obligation, please contact  Nathan Prior, Partner and Head of PWM International.

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