🇬🇧UK Non-Dom in 2026: The Four-Year FIG Window Is Now the Real Planning Story

The four-year FIG window is live, HMRC’s 2026 guidance is out, and globally mobile families are focusing on arrival dates, exit timing, trusts, and inheritance-tax exposure.

What: The UK’s old remittance-basis system ended on 6 April 2025. The replacement Foreign Income and Gains (FIG) regime is now live and operating in the 2025–26 tax year. HMRC published its official FIG helpsheet in May 2026.

Why it matters: New UK arrivals can still claim 100% relief on eligible foreign income and gains — but only for their first four UK tax years, and only if they were non-UK resident for the 10 consecutive years prior. The window is short, mechanical, and unforgiving.

Zoom in: 2026 is the first full year in which real decisions are being tested against these rules: arrive now or later? leave earlier? offshore structures, IHT exposure — all live questions with real stakes for the first time.

The bigger picture: This is the shift from legislative to operational. The reform was announced in 2024, took effect in 2025. But 2026 is when advisers, families, and investors start living with the consequences in practice.

Between the lines: The FIG regime looks generous on paper — 100% relief sounds significant. But the eligibility bar is high, the four-year clock starts on arrival, and one misstep in residence history can void the claim entirely. Planning precision matters more than ever.

Zoom out: The UK has effectively traded a flexible, open-ended non-dom model for a structured, time-limited offer. For globally mobile individuals, the question is whether to arrive in time to use it at all.

For years, the UK’s non-dom regime was one of the best-known features of European private wealth planning. Its logic was domicile-based. A UK resident who was not domiciled in the UK could, in certain circumstances, keep foreign income and gains outside the UK tax net unless those funds were remitted into the country.

That framework has now ended. HMRC states that from 6 April 2025 the remittance basis was abolished, domicile ceased to be the relevant connecting factor for this part of the tax system, and the UK moved to a residence-based model instead. All UK residents are now generally taxed on the arising basis on worldwide income and gains, unless they qualify for a specific relief such as the four-year FIG regime.

The headline benefit for new arrivals is real. A qualifying individual can claim relief on eligible foreign income and gains for the first four tax years of UK residence, and those relieved amounts can be brought into the UK without an extra tax charge. But the architecture is different. This is now a short runway rather than a long shelter.

Why It Matters

The change sounds technical. In practice, it rewrites the planning calendar.

Under the new rules, eligibility depends on whether the individual was non-UK resident for the previous 10 consecutive tax years. That makes residence history decisive. A move to the UK after nine years abroad is a very different proposition from a move after 10 full qualifying years.

Timing inside the UK now matters just as much. The FIG regime is available for a maximum of four consecutive tax years beginning when UK tax residence starts, and unused years do not roll forward. That means arrival date, split-year treatment, and the expected duration of stay now have direct economic consequences. A poorly timed move can waste part of the window.

There is another friction point that will matter for many HNWI families: claiming the regime can come with trade-offs. HMRC says a FIG claim can result in the loss of the personal allowance, the capital gains annual exempt amount, and the use of certain foreign losses for that tax year. That makes the regime attractive, but not automatic. It needs modelling.

The legacy world also has not disappeared overnight. Foreign income and gains arising before 6 April 2025 may still be taxed if remitted to the UK later, although a Temporary Repatriation Facility exists for a fixed three-year period from 2025–26 to 2027–28 to allow certain former remittance-basis users to bring in pre-6 April 2025 amounts on more favourable terms.

Who Should Pay Attention

This matters most for:

• founders considering a relocation before or after a liquidity event
• investors with large non-UK portfolios or expected foreign gains
• families returning to the UK after years abroad
• internationally mobile executives with complex residence histories
• settlors and beneficiaries of offshore trusts
• family offices comparing the UK with Italy, Switzerland, the UAE, or other residence-led planning hubs

The Trust and Structure Question

One of the quietest but most consequential changes sits in the trust rules.

HMRC’s post-6 April 2025 guidance says the old trust protections no longer apply in the same way. In broad terms, where a UK-resident settlor has power to enjoy trust income, income arising in a non-resident trust or its underlying entities can now be taxed on that settlor as it arises. Guidance also confirms that from 6 April 2025 beneficiaries and settlors who qualify under the FIG regime may obtain relief in some cases, but the broader message is clear: offshore trust structures now need to be reviewed through a residence-based lens, not a non-dom lens.

That is especially important for families who built structures for a different era. A trust that made sense under the remittance-basis world may produce very different results once the family becomes UK resident under the new framework.

The Inheritance Tax Shift

The other major quiet border is inheritance tax.

From 6 April 2025, the UK replaced domicile and deemed domicile rules for inheritance tax with long-term UK residence rules. HMRC guidance says a person is long-term UK resident if they are UK tax resident for the previous 10 consecutive years or for at least 10 years within the previous 20. Once that threshold is met, overseas assets may be within the UK inheritance tax net.

Departure is no longer a simple off switch. HMRC says long-term UK residence can continue for up to 10 tax years after leaving, with shorter tails for people who spent fewer years in the UK. The guidance gives examples: someone resident for 10 to 13 years stops being long-term resident three years after departure, while longer residence can produce a longer tail. After 10 consecutive years of non-residence, the test resets.

This is where the planning conversation becomes more strategic. The income tax story may be about a four-year opportunity. The inheritance tax story may be about when not to overstay.

The Global Angle

Seen globally, this is part of a wider repricing of access.

Countries still want internationally mobile entrepreneurs, investors, and families. But they increasingly want them on clearer, more measurable terms. Domicile, deemed domicile, and historic exceptions are giving way to residence tests, time limits, reporting rules, and substance-based exposure.

The UK’s update fits that pattern precisely. It still offers a competitive landing strip for new arrivals. But it no longer offers the same long-duration ambiguity that once made the non-dom regime famous. The benefit is now more legible, more conditional, and more calendar-driven.

For private wealth, that is the larger lesson. Optionality is becoming shorter-dated, more technical, and more dependent on sequencing.

The Strategic Takeaway

The UK may remain attractive for a four-year window. But the planning frame has changed.

The old question was whether someone qualified as non-dom. The new question is more precise: when does UK tax residence start, what do the previous 10 tax years look like, what is sitting in offshore structures, and how close is the family to a longer-term inheritance tax footprint?

This article is for general information only and does not constitute tax, legal, immigration, or investment advice.