UK Expat Remittance Basis 2026 -- After Non-Dom Abolition and FIG Regime

Last reviewed: 26 April 2026

The UK expat remittance basis -- the mechanism that allowed non-UK-domiciled UK residents to pay UK tax only on foreign income and gains that were "remitted" (brought into) the UK -- was abolished from 6 April 2025 by Finance Act 2025 (Schedule 9). The abolition of the UK expat remittance basis is the most significant change to UK international tax rules in a generation: it affects approximately 74,000 people who were previously non-doms using the remittance basis (HMRC estimate). For the UK tax residency rules that determine who was affected and who now qualifies for the new FIG regime, see our UK tax residency guide. For the investment account implications of these changes, see our UK expat investments guide.

The Finance Act 2025 Schedule 9 abolition of the remittance basis has three main elements that the reader of this UK expat remittance basis guide needs to understand: (1) the 4-year FIG regime, which provides a forward-looking exemption for new UK arrivals; (2) the Temporary Repatriation Facility (TRF), which provides a window for existing non-doms to clean up pre-2025 unremitted income and gains at a reduced rate; and (3) the residence-based IHT regime, which replaces the old domicile-based IHT framework from 6 April 2025. The Gov.uk publication "Changes to the taxation of non-UK domiciled individuals" at gov.uk/government/publications/changes-to-the-taxation-of-non-uk-domiciled-individuals is the HMRC primary reference; HMRC’s RDR1 (gov.uk/hmrc-internal-manuals/residence-domicile-and-remittance-basis) is the authoritative technical reference.

The old remittance basis: legacy context

Before 6 April 2025, the UK remittance basis allowed non-UK-domiciled individuals who were UK tax residents to pay UK income tax and CGT only on foreign income and gains that were physically remitted (brought into the UK or used to benefit the taxpayer or their family in the UK). Foreign income and gains that remained offshore were not subject to UK tax while the individual claimed the remittance basis. The mechanism: the individual elected for the remittance basis on their Self Assessment return (SA109); foreign income remained sheltered unless remitted. For UK residents using the remittance basis for 7+ years (of the prior 9 tax years), an annual Remittance Basis Charge (RBC) of £30,000 applied; for 12+ years (of the prior 14 tax years), £60,000 per year. The RBC was a sunk cost that could be worthwhile for individuals with very large amounts of unremitted foreign income. The remittance basis has been abolished for all income and gains arising from 6 April 2025. Income and gains that arose before 6 April 2025 and remain unremitted are dealt with by the TRF (see below). HMRC’s RDR3 (previously, the Remittance Basis guidance) archived version remains relevant for pre-2025 reporting on SA109.

The 4-year FIG regime: the replacement for new UK arrivals

The 4-year FIG (Foreign Income and Gains) regime (Finance Act 2025, from 6 April 2025) provides the forward-looking replacement for the remittance basis for qualifying new UK arrivals. Eligibility: individuals who have not been UK-resident in any of the 10 consecutive tax years prior to becoming UK-resident from 6 April 2025 qualify for the FIG regime. Under the FIG regime: all foreign income and gains (employment income from overseas employers, overseas dividends, overseas rental income, foreign capital gains on overseas assets) are exempt from UK income tax and CGT for the first 4 tax years of UK residency -- regardless of whether the income is remitted to the UK. There is no remittance test; there is no annual charge; the exemption is automatic (though the individual must declare their FIG status on the SA109). The FIG regime is demonstrably simpler than the old remittance basis: no complex clean capital tracking, no "mixed fund" rules, no remittance triggers. However, it is time-limited to 4 years; from year 5, worldwide income is fully UK-taxable. The FIG regime applies to new UK arrivals from 6 April 2025 onwards; it does not apply to those who were already UK-resident before 6 April 2025 (including former non-doms who were UK-resident). HMRC’s guidance on the FIG regime at gov.uk/hmrc-internal-manuals/residence-domicile-and-remittance-basis is the authoritative reference.

Temporary Repatriation Facility (TRF): cleaning up pre-2025 foreign income

The Temporary Repatriation Facility (TRF, gov.uk/government/publications/changes-to-the-taxation-of-non-uk-domiciled-individuals) addresses the treatment of foreign income and gains that arose before 6 April 2025 and remained unremitted while the individual was on the remittance basis. The TRF allows UK-resident individuals (including former non-doms who have now left the UK) to "designate" their pre-2025 unremitted foreign income and gains and bring them to the UK at a flat reduced rate: 12% for income designated and remitted in 2025/26 or 2026/27; 15% for income designated in 2027/28. After 5 April 2028, the TRF window closes; pre-2025 unremitted foreign income remains potentially UK-taxable at full rates on remittance for those who have become UK-resident again. The TRF is particularly relevant for former non-doms who hold large amounts of foreign income accumulated offshore over many years. The TRF flat rate (12% or 15%) is generally significantly lower than the marginal income tax rate (45% additional rate) or CGT rate (24% higher rate for non-property) that would otherwise apply. TRF designations are made via the SA109 supplementary pages for the relevant tax year. The Autumn Budget 2025 OOTLAR (gov.uk/government/publications/autumn-budget-2025-overview-of-tax-legislation-and-rates-ootlar) confirmed the TRF rates and window; specialist tax advice is essential for complex multi-year unremitted income portfolios.

Residence-based IHT: the non-dom replacement

The old IHT domicile rules were also abolished from 6 April 2025 and replaced with residence-based IHT (Finance Act 2025, HMRC guidance at gov.uk/inheritance-tax). Under the old rules: individuals who were not "domiciled" in the UK (broadly, those whose permanent home was in a non-UK country) were subject to UK IHT only on UK-sited assets (not worldwide assets). Under the new residence-based IHT rules from 6 April 2025: individuals who have been UK-resident in at least 10 of the prior 20 tax years are "long-term UK residents" and subject to UK IHT on their worldwide estate -- including overseas property, overseas bank accounts, overseas investments -- during a tail period (up to 10 years) after departure. This change is symmetrical with the remittance basis abolition: just as former non-doms’ foreign income became UK-taxable from 6 April 2025, so too did their worldwide assets fall within the UK IHT estate. The 10-year tail period for former long-term UK residents who have departed means that UK IHT exposure on worldwide assets does not immediately end on leaving the UK. The nil-rate band remains £325,000 (frozen to April 2030); IHT at 40% applies above this on the worldwide estate for long-term UK residents within the tail. HMRC’s IHT guidance at gov.uk/inheritance-tax is the primary reference.

Who still benefits from the transition rules

Three categories of individual still benefit significantly from the Finance Act 2025 transition rules in 2025/26 and 2026/27: (1) New UK arrivals who qualify for the 4-year FIG regime (not UK-resident in any of the prior 10 consecutive tax years from 2025/26) -- they receive 4 years of complete foreign income and gains exemption without any remittance test, annual charge, or complex tracking; (2) Former non-doms with large pre-2025 offshore income pools who can use the TRF to bring funds to the UK at 12% in 2025/26 or 2026/27 -- significantly cheaper than full UK income tax rates; and (3) Individuals who were already non-UK-resident before 6 April 2025 (and who therefore never had remittance basis issues arising from 6 April 2025 onwards) -- their offshore income from their period of non-residency remains outside UK tax and they face no TRF obligation. Former UK non-doms who were UK-resident on 6 April 2025 and had claimed the remittance basis face the most complex transition: their worldwide income from 6 April 2025 is fully UK-taxable (unless they qualify for the FIG regime, which requires 10 years of prior non-residence); their pre-2025 unremitted income is addressable via TRF; and their worldwide estate is within the new IHT framework. Specialist UK cross-border tax advice (from a CIOT-qualified adviser) is essential for this group. HMRC’s SA109 guides the reporting requirements.

SA109 reporting changes post-2025

The SA109 (Residence, Remittance Basis etc.) supplementary form has been updated for 2025/26 to reflect the Finance Act 2025 changes to the UK expat remittance basis. Key changes: the boxes previously used to elect for the remittance basis and to declare the Remittance Basis Charge have been removed for income arising from 6 April 2025; new boxes are available for the FIG regime election (for qualifying new UK arrivals) and the TRF designation (for former non-doms designating pre-2025 unremitted income). Non-UK-residents who have UK-source income are not directly affected by the remittance basis abolition (they were not using the remittance basis -- they were simply not UK-resident); their SA109 continues to be used to declare non-UK-residency and claim DTC relief. Former non-doms who were UK-resident on 5 April 2025 and who now wish to use the TRF must make the TRF designation in their 2025/26 Self Assessment return (online deadline: 31 January 2027) or in their 2026/27 return (deadline: 31 January 2028). The SA109 form and notes for 2025/26 are at gov.uk/government/publications/self-assessment-residence-remittance-basis-etc-sa109; the TRF guidance at gov.uk/government/publications/changes-to-the-taxation-of-non-uk-domiciled-individuals covers the designation mechanics.

This article is for general information only and does not constitute tax, legal, financial or immigration advice. Rules and rates change; verify with the primary sources cited or consult a qualified adviser before acting.

FAQ

Is the UK remittance basis still available from 6 April 2025?

No. The remittance basis was abolished from 6 April 2025 by Finance Act 2025 Schedule 9. Income and gains arising from 6 April 2025 are not eligible for the remittance basis; all UK residents are taxed on worldwide income from day one unless they qualify for the 4-year FIG regime. Pre-2025 unremitted income and gains can be addressed via the Temporary Repatriation Facility (TRF). HMRC’s guidance at gov.uk/government/publications/changes-to-the-taxation-of-non-uk-domiciled-individuals is the authoritative reference.

Who qualifies for the 4-year FIG regime?

Individuals who have not been UK-resident in any of the 10 consecutive tax years before the tax year in which they become UK-resident from 6 April 2025 qualify. Under the FIG regime, all foreign income and gains are exempt from UK tax for the first 4 tax years of UK residency -- no remittance test, no annual charge, no mixed fund tracking. UK-source income remains taxable from day one. HMRC’s FIG guidance at gov.uk/hmrc-internal-manuals/residence-domicile-and-remittance-basis confirms eligibility requirements.

What is the Temporary Repatriation Facility and how does it work?

The TRF allows former non-doms who had unremitted foreign income or gains arising before 6 April 2025 to bring those funds to the UK at a flat reduced tax rate: 12% for designations made in 2025/26 or 2026/27; 15% for designations made in 2027/28. After 5 April 2028, the TRF window closes. TRF designations are made via the SA109 supplementary pages in the relevant Self Assessment return. Specialist cross-border tax advice is essential for complex pre-2025 offshore income portfolios before making TRF designations.

How has UK IHT changed for former non-doms?

Finance Act 2025 (from 6 April 2025) replaced domicile-based IHT with residence-based IHT. Individuals UK-resident in at least 10 of the prior 20 tax years are long-term UK residents subject to UK IHT on their worldwide estate during a tail period (up to 10 years after departure). The old non-dom IHT exemption for non-UK assets has been abolished for new long-term UK residents from 6 April 2025. The nil-rate band remains £325,000 (frozen to April 2030). HMRC’s IHT guidance at gov.uk/inheritance-tax covers the new rules.

Do I still need to track clean capital after the remittance basis abolition?

No, for income and gains arising from 6 April 2025. The complex "mixed fund" and clean capital tracking rules under the old remittance basis apply only to pre-6 April 2025 unremitted income pools. For the FIG regime (applicable from 6 April 2025 for new UK arrivals), there is no remittance test and therefore no clean capital tracking requirement. Former non-doms should continue tracking pre-2025 unremitted income if they plan to use the TRF rather than designate all pre-2025 funds at once. CIOT-qualified specialist advice is required.

How do I make a TRF designation on my tax return?

TRF designations are made via the SA109 supplementary pages of the UK Self Assessment return for the relevant tax year (2025/26 deadline: 31 January 2027; 2026/27 deadline: 31 January 2028). The SA109 updated for 2025/26 includes specific boxes for TRF designation. The taxpayer designates the amount of pre-2025 unremitted foreign income or gains being remitted under the TRF, and the 12% or 15% flat rate is applied via Self Assessment. The HMRC guidance at gov.uk/government/publications/changes-to-the-taxation-of-non-uk-domiciled-individuals covers the mechanics in detail.

Sources

1. GOV.UK -- Changes to the taxation of non-UK domiciled individuals (FIG regime, TRF 12%/15%, Finance Act 2025) (verified 26 April 2026)
2. HMRC -- RDR1: Residence, Domicile and Remittance Basis (FIG regime and post-2025 IHT) (verified 26 April 2026)
3. GOV.UK -- UK IHT: residence-based IHT from 6 April 2025 (10-year long-term resident rule) (verified 26 April 2026)
4. HMRC -- SA109 Residence Remittance Basis form (updated for FIG and TRF designation) (verified 26 April 2026)
5. GOV.UK -- Autumn Budget 2025 OOTLAR (TRF confirmation and Finance Act 2025 measures) (verified 26 April 2026)