Last updated: 16 October 2026
What happened to non-dom status?
From 6 April 2025, the UK abolished the remittance basis for non-domiciled residents. Domicile no longer decides how foreign income and gains are taxed. Instead, the system is based on tax residence. The changes prompted reports of wealthy individuals, including some who were never non-doms, considering leaving the UK, although estimates of how many have actually left vary widely.
The four-year FIG regime
New arrivals who have not been UK resident in any of the previous ten tax years can claim full relief from UK tax on foreign income and gains (FIG) for their first four years of UK residence. They can bring the money to the UK without extra tax. After four years, they are taxed on worldwide income and gains as they arise.
Inheritance tax is now residence-based
| Status | IHT on worldwide assets? |
| UK resident for at least 10 of the last 20 tax years (long-term resident) | Yes |
| Not a long-term resident | Only on UK assets |
| Long-term resident who leaves the UK | Stays in scope for a “tail” of 3 to 10 years, depending on how long they were resident |
Transitional rules
- Temporary Repatriation Facility (TRF): former remittance basis users can bring pre-April 2025 foreign income and gains to the UK at a reduced rate of 12% in 2025/26 and 2026/27, and 15% in 2027/28.
- Rebasing: former remittance basis users can rebase personal foreign assets to their value on 5 April 2017 for CGT, if conditions are met.
- Trusts: offshore trusts no longer protect income and gains from tax for UK resident settlors, and excluded property status for IHT now depends on the settlor’s long-term residence.
Why some people are leaving
For long-term residents with substantial foreign assets, the move to worldwide IHT at 40% and the end of the remittance basis can mean much higher tax. Destinations such as Italy, Switzerland, the UAE and Monaco have been mentioned in reports. But leaving does not end UK exposure immediately: the statutory residence test and the IHT tail apply.
Example
Carlos moved to the UK in 2012 and claimed the remittance basis. From April 2025 he is taxed on his worldwide income. He has £2 million of pre-2025 foreign income held offshore. Using the TRF, he can bring it to the UK at 12% tax (£240,000) in 2026/27, instead of paying up to 45% if it were remitted later under the old rules.
Planning points
- Check residence status for each year under the statutory residence test.
2. Consider the TRF before the rate rises to 15% in April 2027.
3. Review wills and trusts in light of the IHT changes.
4. Keep records of foreign income and gains by year and source.
Frequently asked questions
Does domicile still matter at all?
Very little for tax. It may still matter for some older trusts and for non-UK law.
Do I have to claim the four-year regime?
Yes, on your Self Assessment return each year, and claiming means losing your personal allowance.
Can British citizens returning from abroad use it?
Yes, if they were non-resident for the previous ten years.
Is the TRF available after 2028?
No. It ends after 2027/28.
Related: how 2025 changes affect your status, IHT for returning expats and offshore investments and IHT.
Talk to Accotax
Want this handled for you? Our team at Accotax can help with non-dom and residence tax planning. See our personal tax accountants service, or contact us for a free, no-obligation quote.
This page is general guidance based on HMRC rules for the 2026/27 tax year, checked against gov.uk on 16 October 2026. It is not personal advice, so speak to an accountant about your own situation.
