New UK Foreign Income & Gains (FIG) regime: what you need to know

From 6 April 2025, the UK is introducing major changes to how foreign income and gains are taxed for individuals who move (or return) to the UK after 10 years abroad. The old “remittance basis” is being replaced by a new Foreign Income & Gains (FIG) regime:

FIG Regime: Qualifying new arrivals, those who have been non-UK resident for at least 10 consecutive years, can enjoy up to 4 tax years with no UK tax on their foreign income and gains, whether or not the money is brought into the UK. However, they won’t get personal allowances or capital gains exemptions during these years.
Transition Periods: If they returned to the UK from 2022/23 onwards and meet the 10-year non-residence requirement, you may qualify for FIG from April 2025.
End of Remittance Basis: The old remittance basis, available to non-UK domiciled UK residents, meant foreign income and gains were only taxed if brought (“remitted”) into the UK. This rule ends on 5 April 2025.
Temporary Repatriation Facility (TRF): For two years (2025/26 and 2026/27), there’s a special opportunity to bring previously unremitted foreign income and gains into the UK at a flat tax rate of 12% (or 15% in the second year), which is much lower than standard rates.
Long-term UK Residents: If an individual has been living in the UK for many years, even as a non-dom, but have not been non-UK resident for at least 10 consecutive years, they will not qualify for the FIG regime. From April 2025, they will simply be taxed on their worldwide income and gains, and the remittance basis will no longer be available.
(In reality, for most people, after 7 years of UK residence, they would already be paying UK tax on their worldwide income and gains unless they paid the significant remittance basis charge, so these changes mainly impact those who are new or returning to the UK after a long period abroad.)

The FIG regime offers a significant short-term tax break for new UK arrivals, and the TRF gives a limited window to bring old offshore funds into the UK at a low tax rate. However, long-term UK residents will move to full worldwide taxation from April 2025, regardless of domicile status.

If you’d like to discuss what these changes might mean for you, feel free to get in touch by emailing info@streets.uk or visit www.streets.uk

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