While these reforms bring an end to the long-standing remittance basis, they also introduce new opportunities for tax-efficient planning, particularly through the Temporary Repatriation Facility (TRF) and the four-year Foreign Income and Gains (FIG) regime.

Background: The end of the remittance basis

Historically, non-doms could elect to be taxed on the remittance basis, meaning they only paid UK tax on foreign income and gains (FIG) if and when those funds were brought into the UK. This allowed for significant deferral - and in some cases, avoidance - of UK tax on offshore wealth.

From April 2025, this has changed. All UK residents are now taxed on their worldwide income and gains, regardless of domicile status. The concept of domicile has become largely irrelevant for income tax, capital gains tax, and inheritance tax purposes, replaced by a residence-based framework.

While media reports suggest a potential exodus of wealthy non-doms from the UK, these changes also create valuable planning opportunities for both non-doms and non-UK residents.

The Temporary Repatriation Facility (TRF)

To ease the transition, the government has introduced a Temporary Repatriation Facility, available for three tax years (2025–2028). This facility allows individuals who previously used the remittance basis to bring foreign income and gains into the UK at reduced tax rates:

• 12% for the first two years (2025-26 and 2026-27)
• 15% in the final year (2027-28)

This presents a significant opportunity for individuals with mixed funds - accounts containing a blend of income, gains, and capital - to repatriate funds at a preferential rate, rather than facing full marginal tax rates. It potentially unlocks the ability to bring capital into the UK without incurring further taxation.

Importantly, the TRF also applies to unattributed income and gains held in trust structures, offering a rare window to unlock value from complex offshore arrangements.

However, it is crucial to consider whether these funds are likely to be needed in the UK. While the TRF rates are significantly lower than the potential 45% income tax rate, they are still higher than the 0% that would apply if the funds were left offshore indefinitely.

The four-year FIG regime

For individuals moving to the UK after 10 consecutive years of non-residence, a new four-year FIG regime now applies. Under this regime, qualifying individuals enjoy full UK tax exemption on foreign income and gains for their first four tax years of UK residence.

This relief is available to both new arrivals and returning UK nationals ("Brits abroad") who meet the 10-year non-residence condition. It provides a powerful incentive to strategically structure global income streams and asset disposals during this window.

Key planning opportunities:

• Realising offshore gains during the four-year period without UK tax exposure
• Reinvesting funds into tax-efficient structures for UK or future country of residence
• Deferring UK-sourced income until after the FIG period ends
• Using offshore trusts or holding companies to manage income flows efficiently

Strategic considerations

Given the scope of these reforms, individuals affected should consider:

• Reviewing offshore structures to identify mixed funds and assess eligibility for the TRF
• Timing asset disposals to fall within the four-year FIG window
• Rebasing foreign assets to their 5 April 2017 value (available for past remittance basis users)
• Reassessing UK residency plans , especially for those considering a return to the UK

Conclusion

While the end of the remittance basis marks a significant change, the UK’s new non-dom regime offers valuable planning opportunities for those who act early. The TRF and four-year FIG regime provide a rare chance to restructure offshore wealth and enter the UK tax net on favourable terms.

As always, tailored professional advice is essential. The complexity of these changes - and the limited time windows involved - mean that proactive planning is more important than ever.