Wealth Management in the UK for Non-Domiciled Residents: 2025 Reform Guide

April 2025 marked one of the most significant changes to UK taxation for internationally mobile individuals in a generation. The abolition of the remittance basis and its replacement with a new Foreign Income and Gains (FIG) regime fundamentally altered the tax position of non-domiciled UK residents. For those who relied on the remittance basis to shelter offshore income and gains from UK tax, the reform has required a comprehensive review of their wealth management arrangements.

This guide explains what changed, what planning opportunities remain, and how non-dom residents should structure their wealth and financial affairs as of 2026.

What Was the Remittance Basis?

Until April 2025, non-UK domiciled individuals resident in the UK could elect to be taxed on the remittance basis: they paid UK tax only on UK-source income and gains, and on overseas income and gains that they physically brought into (remitted to) the UK. Offshore income and gains that remained outside the UK were not subject to UK tax, regardless of the amounts involved.

The remittance basis was free to use for the first seven years of UK residence. After that, an annual charge applied: £30,000 per year for those resident for 7 out of 9 preceding years, and £60,000 per year for those resident for 12 out of 14 years (before the regime's abolition). After 15 years of UK residence, individuals became deemed domiciled in the UK and the remittance basis was no longer available.

The April 2025 Reform: The FIG Regime

From 6 April 2025, the remittance basis was abolished and replaced with the Foreign Income and Gains (FIG) regime. Under the FIG regime:

• Individuals who arrive in the UK and have not been UK resident in the preceding 10 tax years receive a complete exemption from UK tax on foreign income and gains for their first four tax years of UK residence, regardless of whether funds are remitted to the UK
• After four years of UK residence, the FIG exemption ceases and the individual becomes subject to UK tax on worldwide income and gains in the same way as any UK resident

This is a simpler regime than the old remittance basis — no annual charge, no tracking of remittances — but it provides full relief for only four years rather than the effectively indefinite protection that wealthy long-term non-doms previously enjoyed.

Transitional Provisions

For individuals who were already UK resident when the reform took effect, transitional provisions apply:

• Temporary Repatriation Facility (TRF): individuals with pre-6 April 2025 unremitted foreign income and gains can elect to "designate" those amounts and bring them into the UK during the three-year TRF window (2025–26 to 2027–28) at a reduced flat rate of 12% (rising in later years). This provides a significant incentive to regularise previously unremitted offshore income
• Rebasing of foreign assets: certain personally held foreign assets owned by eligible former remittance-basis users as at 5 April 2017 can be rebased to their value on that date for capital gains tax purposes (for disposals on or after 6 April 2025), reducing the taxable gain on future disposal
• Existing structures: offshore trusts settled by non-doms before April 2025 may retain some protection, but the rules are complex and highly fact-specific; specialist advice is essential

Inheritance Tax Changes

The April 2025 reform also made fundamental changes to UK inheritance tax (IHT) for long-term residents. Previously, UK IHT applied to the worldwide assets of UK-domiciled individuals and to UK-sited assets of non-domiciled individuals. Domicile was a key determining factor.

Under the new rules (effective from 6 April 2025), UK IHT applies to the worldwide assets of long-term UK residents — defined as individuals who have been UK resident for at least 10 of the 20 tax years immediately preceding the tax year in question. The concept of domicile has been substantially replaced by this residence-based test for IHT purposes.

Critically, the IHT "tail" for long-term residents is up to 10 years: an individual who leaves the UK after 10 or more years of residence remains within the scope of UK worldwide IHT for a sliding period of 1–10 years after departure, depending on how long they were resident.

This change is highly significant for non-doms who were previously protected from UK IHT on foreign assets by their non-dom status: they may now face UK IHT on worldwide assets even if they leave the UK.

What Planning Remains Available?

Despite the scale of the reform, a number of meaningful planning strategies remain available for non-dom residents.

The FIG Regime Window

New arrivals to the UK who have not been resident for the preceding decade receive four years of complete exemption on foreign income and gains. This is a genuine and substantial benefit that new arrivals should use fully. During the FIG period, there is no cost to accumulating investment returns offshore (or remitting them to the UK), making it the ideal time to:

• Restructure offshore portfolios free of UK tax
• Realise significant gains on existing investments
• Build up investment accounts that will subsequently be funded by UK-taxed income

Offshore Trusts: Residual Protection

Offshore trusts settled before 6 April 2025 by non-dom settlors retain some residual tax advantages, though far fewer than under the old regime. Advice on the ongoing tax treatment of existing trusts — and whether it makes sense to continue them, amend their terms, or collapse them — should be sought urgently if not already obtained.

For trusts settled after April 2025, the rules are less favourable: settlor-interested trusts will generally be transparent for UK income tax and CGT purposes, with trust income and gains attributed to the settlor.

Excluded Property

The excluded property rules for IHT purposes — which previously provided that non-UK sited assets of a non-dom settled into a trust were excluded from UK IHT — have been substantially amended. Under the new rules, assets in trusts settled by long-term UK residents may no longer qualify as excluded property. The timing of trust settlement, the settlor's UK residence position, and the siting of assets all matter. Again, specialist advice is essential.

Pension Planning

UK registered pensions (SIPPs and occupational schemes) retain their UK tax advantages, including income tax relief on contributions (subject to the Annual Allowance, £60,000 in 2026) and tax-free growth within the fund. The 2024 Budget announced that pension funds will be brought within the scope of IHT from 2027; this remains a significant planning consideration. Non-dom residents who are within the FIG window should consider the optimal timing of pension contributions relative to their overall wealth structure.

Business Investment Relief

Business Investment Relief (BIR) allows non-doms (and, post-reform, individuals within the FIG period) to remit foreign income and gains to the UK without triggering a remittance tax charge, provided the funds are invested within 45 days into a qualifying UK trading business or holding company. BIR was used extensively under the old regime and remains available in modified form for FIG individuals. It is particularly relevant for non-dom entrepreneurs who wish to invest in UK businesses using offshore funds.

The Temporary Repatriation Facility

The TRF is arguably the most time-sensitive planning opportunity arising from the reform. For individuals with substantial offshore unremitted income or gains accumulated before April 2025, the ability to designate and bring those funds into the UK at a flat 12% rate (for 2025–26 and 2026–27) represents a potentially significant tax saving. The window closes in April 2028, after which the standard rules apply to any remaining unremitted amounts.

Practical Steps for Non-Dom Residents

If you are a non-dom resident who has not yet reviewed your position in light of the April 2025 reform, the following steps are urgent:

1. Assess your FIG eligibility: are you within the four-year window, or did you already exhaust it?
2. Quantify unremitted income and gains: how much is sitting offshore and what were the tax years in which it arose? This determines TRF eligibility
3. Review existing offshore trusts: what is the continuing UK tax position and does it still make sense to maintain the structures?
4. Review IHT exposure: assess your UK residence history and project forward to understand when (or whether) you will become a long-term resident for IHT purposes
5. Consider departure planning: if you are approaching 10 years of UK residence and wish to preserve access to the FIG regime or avoid the long-term resident IHT rules, departure timing becomes critical

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This guide is for educational purposes only and does not constitute regulated financial, tax, or legal advice. UK tax law continues to evolve; always seek current qualified advice before acting. Tax rates and rules referenced are correct as of 2026 but are subject to change.

How Global Investments Can Help

The April 2025 non-dom reforms have created one of the most complex planning environments for internationally mobile individuals in recent memory. Global Investments works with specialist UK tax advisers and international lawyers to help non-dom clients understand their changed position, quantify their exposure, and implement appropriate structures — including TRF elections, trust reviews, pension planning, and IHT mitigation strategies.

We take a coordinated view across all relevant jurisdictions, ensuring that any restructuring in response to the UK reforms does not inadvertently create new problems elsewhere. If you have not yet had a comprehensive review since April 2025, please contact us as a matter of priority.