From Non-Dom to FIG: What Long-Term UK Residents Should Do Now

The FIG regime is good news for new arrivals. For people who have lived in the UK for years and used the remittance basis, the change is more complicated — and it comes with a time-limited opportunity that most people should at least price up before it closes.

What changed for you

From 6 April 2025 the remittance basis was abolished. If you have been UK resident for more than four years, you are now taxed on your worldwide income and gains as they arise, in the same way as anyone else. Domicile no longer decides your income tax or capital gains tax position.

The old money problem

Income and gains you kept offshore under the remittance basis in earlier years remain taxable if you bring them to the UK. That is why so many long-term residents have offshore accounts they are reluctant to touch: the funds are effectively locked behind a 45% charge.

The Temporary Repatriation Facility

The Temporary Repatriation Facility (TRF) lets former remittance-basis users designate that old offshore income and gains and pay a flat charge, after which the money can be brought to the UK with no further tax:

• 2025/26 — 12%
• 2026/27 — 12%
• 2027/28 — 15%

After 2027/28 the facility closes. Designation is made on your Self Assessment return, and once designated the funds are "clean" — you can remit them in a later year without further UK tax.

Why this is worth modelling now

A 12% charge against a marginal rate of 45% on income, or 24% on residential property gains, is a substantial discount. But the calculation depends on how well you can identify what is in each account, whether the money is income, gain or clean capital, and whether you will realistically ever want it in the UK. Mixed funds — where salary, dividends and capital all sit in one account — need to be analysed before you designate.

Rebasing

There is also a capital gains tax rebasing to 5 April 2017 available to individuals who meet the conditions, which can reduce the gain on foreign assets you already held. It is a one-off, and it only helps if you actually dispose of the asset.

Inheritance tax is now about residence

IHT no longer follows domicile. Broadly, once you have been UK resident for ten of the previous twenty tax years you become a "long-term resident" and your worldwide estate is within the UK IHT net — and there is a tail of up to ten years after you leave. If you have historically relied on excluded property trusts or a non-UK domicile, your estate plan needs reviewing.

Frequently asked questions

Can I use the FIG regime as a long-term resident?

Only if you leave the UK and stay non-resident for ten consecutive tax years, then return. For most people the answer is no.

Do I have to designate everything at once?

No. You can designate as much or as little as you choose in each of the three years, which lets you spread the charge across tax years.

What if I cannot identify what is in an old account?

This is normal for accounts that have run for twenty years. There are pragmatic approaches and, in some cases, a designation of the whole balance is cheaper than the analysis. Bring us the statements and we will tell you.

I am a US citizen who has been in the UK for years. Does the TRF create a US problem?

It can. A TRF charge is a UK tax that may or may not be creditable against your US liability in the year it arises, and timing matters. Do not designate without modelling both sides.

Deadlines that matter

The 2026/27 designation is made on the return due 31 January 2028, but the 12% rate is only available for that year — waiting until 2027/28 costs 15%. If you have offshore funds you may want in the UK, this is a 2026 conversation, not a 2028 one.