Arriving in the UK to settle is not a single event for tax purposes. It is a sequence of statutory triggers across the Statutory Residence Test (SRT), the new Foreign Income and Gains (FIG) 4-year window, NRCGT on any pre-arrival UK property disposal, Non-Resident Landlord (NRL) cessation, the new Long-Term Resident (LTR) clock for IHT and (for returning UK nationals) the TCGA 1992 s.10A symmetric temporary-non-residence trap. The two operative entry points are the FIG regime under ITTOIA 2005 ss.845A to 845J (inserted by FA 2025 s.37) and the LTR test under IHTA 1984 ss.6A to 6C. Both are residence-based; both were introduced or rewritten by FA 2025 from 6 April 2025; both displace the historic "non-dom" framing that dominated inbound advice pre-2025.

The popular shorthand "new arrivals get 4 years tax-free on foreign income" is wrong on three counts. First, FIG requires a per-year claim under s.845A; failing to claim forfeits that year's relief. Second, claiming FIG forfeits the UK personal allowance, the dividend allowance and the CGT annual exempt amount in each claim year, so net benefit only arises where foreign income or gains for that year exceed the lost-allowance value (roughly £25,000 to £30,000 at additional rate). Third, the gateway is 10 tax years of prior non-UK-residence per s.845B(1)(b), not 4. A landlord last UK-resident in 2019/20 cannot claim FIG until 2030/31 at the earliest.

The single most misexplained corner of the inbound regime is the FA 2025 Schedule 11 CGT rebasing election to 5 April 2017 value. Condition 3 in paragraph 1(1) excludes UK situs assets absolutely. An inbound non-dom holding a London BTL bought pre-arrival cannot rebase it under Schedule 11; UK property has its own narrower NRCGT-specific rebasing dates only (5 April 2015 residential, 5 April 2019 non-residential). This page walks the inbound decision tree, the SRT split-year Cases 4 to 8 (paragraphs 44 to 48 of FA 2013 Schedule 45 Part 3), the FIG eligibility test with two worked contrasts, the rebasing trap, NRCGT on any pre-arrival UK property disposal, NRL turn-off mechanics, the LTR clock with an HNW worked example, the Temporary Repatriation Facility for returning UK non-doms, and 14 of the most common inbound landlord questions. For the outbound mirror (UK landlord moving overseas permanently) see our are you leaving the UK permanently page. For the short-term-departure variant see our UK property income for expats page.

The inbound decision tree

In the first conversation about a UK move, walk this twelve-step sequence with a tax adviser before the arrival date.

  1. Identify your residence year-by-year via SRT. FA 2013 Schedule 45 Part 1 cascade: automatic overseas tests first, then automatic UK tests, then sufficient ties. Your arrival date does not trigger UK residence by itself; the tax year's day count and ties determine the position.
  2. Check split-year Cases 4 to 8 for the arrival year. Case 4 (starting to have only a UK home); Case 5 (starting full-time UK work); Case 6 (ceasing full-time overseas work); Case 7 (partner of a Case 6 individual); Case 8 (starting to have a UK home). Where multiple cases could apply, statute determines priority per paragraphs 53 to 55. Split-year is not optional.
  3. Inventory your prior-10-years residence position. To claim FIG under ITTOIA 2005 s.845B(1), you need to have been non-UK-resident for each of the 10 tax years preceding the current tax year (gateway). Verify each year against your day-count records. If you were UK-resident in any of the previous 10 tax years, FIG is not available; you enter as an arising-basis resident from day one.
  4. Decide whether to claim FIG year by year. Claiming under s.845A is per-year and irrevocable for that year. The claim costs your UK personal allowance (£12,570 frozen to April 2028), dividend allowance (£500) and CGT annual exempt amount (£3,000). Claim only where your foreign income or gains exceed the lost-allowance value (roughly £25,000 to £30,000 at additional rate).
  5. Inventory your UK property holdings before the arrival date. Any UK property disposal made while still non-resident is NRCGT under TCGA 1992 s.1A. The 60-day NRCGT return is required regardless of tax due. UK rental income falls within ITTOIA 2005 Part 3 or CTA 2009 Part 4 regardless of your residence.
  6. Stop the NRL withholding from the residence start date. Once your SRT analysis makes you UK-resident, the FA 1995 Schedule 23 NRL withholding obligation falls away from that date. Notify letting agents and tenants in writing; complete the NRL6 close-out paperwork; self-assess on SA100 plus SA105 going forward.
  7. Check your inbound IHT position under IHTA 1984 ss.6A to 6C. You become LTR (worldwide-IHT exposure) once UK-resident in 10 of the preceding 20 tax years. For a first-time arrival, the clock starts at year 1 of UK residence; LTR exposure triggers at year 10 (typically). Pre-arrival estate planning has a window before the clock starts.
  8. Returning UK nationals: check s.10A. If you left the UK 5 or fewer years ago, were UK-resident in 4 or more of the 7 tax years before departure, and sold non-UK assets during non-residence, those gains are deemed to arise in your year of return under TCGA 1992 s.10A. The CGT crystallises now (year of arrival), not when you originally sold.
  9. Returning non-doms with pre-2025 unremitted accumulations: consider TRF. Per FA 2025 Schedule 10, designation at 12% (2025/26), 12% (2026/27), 15% (2027/28); window closes 5 April 2028. A pre-2025-26 remittance-basis user returning to UK can designate the pool at TRF rate to crystallise it as clean capital.
  10. Inbound non-doms holding pre-arrival UK property: rebasing is not available. Per FA 2025 Schedule 11 paragraph 1(1) condition 3, UK situs assets are excluded. The London BTL acquired in 2019 cannot be rebased to 5 April 2017 value; the only UK-land rebasing dates are 5 April 2015 (residential) or 5 April 2019 (non-residential) under the NRCGT regime.
  11. Check source-state DTA tie-breakers for the arrival year. If you remain dual-resident under SRT (UK) and source-state domestic law for part of the arrival year, OECD Model Article 4 tie-breaker cascade applies (permanent home, centre of vital interests, habitual abode, nationality, mutual agreement). Cross-link to country-specific DTA pages for bilateral detail.
  12. Engage specialist representation pre-arrival. Pre-arrival timing of foreign-asset disposals, pension-pot positioning, share-vesting events and trust distributions matters materially. Post-arrival the planning window narrows dramatically.

The Statutory Residence Test in the arrival year

FA 2013 Schedule 45 Part 1 sets out the three-stage cascade. The first stage is the automatic overseas tests. If any one is met, you are non-UK-resident for the tax year regardless of UK days or UK ties. The day-count test floors are 16 UK days (if you were UK-resident in any of the preceding 3 tax years) and 46 UK days (if you were not). The full-time-overseas-work test requires the 35-hour working pattern overseas with limits on UK workdays and UK visits.

The second stage is the automatic UK tests. If any one is met (and no automatic overseas test is met), you are UK-resident. The 183-day test catches anyone in the UK for 183 days or more in the tax year. The only-home test catches someone whose only home is in the UK for 91 or more consecutive days. The full-time UK work test catches someone working full-time in the UK for at least 365 days with limits on overseas-work breaks.

The third stage is the sufficient-ties test. Where no automatic test is met, the SRT combines UK ties (family, accommodation, work, 90-day, country) with UK day count per the HMRC RDR3 Annex A table. Arrivers (people not UK-resident in any of the preceding 3 tax years) need progressively more ties to become UK-resident at lower day counts.

For arrivals, the split-year provisions in Schedule 45 Part 3 can apportion the arrival year. Five cases apply to arriving individuals. Case 4 (paragraph 44, starting to have only a UK home) splits the year on the date you cease to have a non-UK home. Case 5 (paragraph 45, starting full-time UK work) splits on the date you start full-time UK work meeting the 35-hour test. Case 6 (paragraph 46, ceasing full-time overseas work) splits on the date overseas full-time work ceases. Case 7 (paragraph 47) covers the partner of a Case 6 individual; the split-date is the partner's split-date or the date the relationship-and-cohabitation test is satisfied, whichever is later. Case 8 (paragraph 48, starting to have a UK home) splits on the date the UK home is acquired while an overseas home is retained.

Where multiple cases could apply, statute determines priority under paragraphs 53 to 55. Cases 4 and 8 contest the UK-home boundary; Case 4 takes precedence where the previous non-UK home is given up, Case 8 where it is retained. Cases 5 and 6 contest the work-pattern boundary. Split-year is not optional and not elective; the cases either apply (and bind the apportionment) or they do not. Specialist analysis on the day count, the work pattern, the home position and the relationship status is required to determine which case (if any) applies in a borderline year.

The FIG 4-year window: eligibility and the lost-allowance trade-off

The Foreign Income and Gains regime under ITTOIA 2005 Chapter 5 ss.845A to 845J (inserted by FA 2025 s.37 and Schedule 8, effective tax year 2025/26) replaces the abolished remittance basis for new arrivals. It is not the same regime under a different name. The gateway test, the claim mechanism, the cost in lost allowances and the income categories within scope differ materially from the historic remittance basis.

The gateway under s.845B(1) has four cumulative conditions: (a) UK-resident for the current tax year; (b) not UK-resident for each of the 10 tax years before that tax year; (c) not disqualified per s.845B(2); (d) individual at least 10 years old at the start of the tax year. Condition (b) is the operative inbound filter. The 10-of-prior-10 gateway means an individual last UK-resident any time in the preceding 10 tax years does not qualify.

The claim mechanism under s.845A is per-year. The claim is irrevocable for the year claimed; failing to claim forfeits that year's relief. The deadline is 31 January 12 months after the end of the relevant tax year. For tax year 2025/26, the deadline is 31 January 2028. For 2026/27, 31 January 2029. This is not the TMA 1970 s.43 generic 4-year amendment window; FIG has its own bespoke claim deadline. Once the deadline passes, the year's relief is lost permanently.

The cost of claiming FIG in any tax year is forfeiture of the UK personal allowance (£12,570 frozen to 5 April 2028), the dividend allowance (£500 from April 2024) and the CGT annual exempt amount (£3,000). At additional rate (45%), the lost-allowance cost is roughly £7,200 of additional tax exposure on the would-have-been-sheltered income. Break-even is therefore approximately £25,000 to £30,000 of foreign income or gains per claim year at additional rate; lower at basic rate (20%) or higher rate (40%).

The income within scope under s.845H is broad (around 22 to 23 distinct categories including foreign property income, foreign trade profits, foreign pensions, foreign interest, foreign dividends, foreign annuities). The anti-fragmentation rules in s.845I exclude UK-derived income routed through offshore vehicles; HMRC will treat fragmented income as remaining UK-source for FIG purposes.

Example one: Mrs Khoury, first-time arrival from Lebanon

Mrs Khoury (Lebanese citizen; never previously UK-resident; arrives London October 2026 with husband and two children; intends to settle long-term; brings approximately £4.2m investment portfolio held with Beirut and Geneva private banks generating £180,000 of foreign dividend, interest and bond-coupon income annually; also holds a Lebanese rental flat generating £45,000 a year; planning to purchase a £3.5m London family home and a £1.2m London BTL once settled).

SRT 2026/27 arrival year: depending on UK day count and work pattern, likely Case 4 or Case 8 (UK home acquired while Beirut flat retained, so Case 8 splits the year on the UK-home acquisition date). If her husband starts full-time UK work, Case 5 may apply with Case 7 covering her as partner. Split-year apportions the tax year so pre-October 2026 foreign income is outside UK scope even though she is UK-resident for the whole 2026/27 year.

FIG eligibility: Mrs Khoury has been non-UK-resident for every tax year before 2026/27 (10-of-prior-10 gateway clearly met per s.845B(1)); aged over 10; not disqualified. ELIGIBLE. She can claim FIG for each of tax years 2026/27, 2027/28, 2028/29 and 2029/30 (4-year window). FIG claim economics: annual foreign income £225,000 (£180,000 portfolio + £45,000 Lebanese rental). Lost-allowance cost (personal allowance £12,570 + dividend allowance £500 + CGT AEA £3,000 = £16,070) at additional rate 45% is approximately £7,200 a year of additional tax exposure. Net FIG saving: £225,000 at 45% = £101,250 of UK tax avoided minus £7,200 lost-allowance cost equals approximately £94,000 net saving a year. Claim. Total 4-year FIG benefit approximately £376,000.

FIG claim deadlines: 31 January 2028 for 2026/27; 31 January 2029 for 2027/28; 31 January 2030 for 2028/29; 31 January 2031 for 2029/30. Late claim forfeits the year. UK property income (post-purchase): the London BTL purchased after arrival generates UK property income, UK-taxable under ITTOIA 2005 Part 3 from purchase date regardless of FIG status. FIG covers foreign income and gains only. UK property purchases: SDLT scope. The £3.5m London family home triggers SDLT at residential rates plus 5% additional-dwelling surcharge from 31 October 2024 if she already owns the Lebanese property at completion. First-time-buyer relief is not available (she owns the Lebanese flat). The £1.2m BTL triggers SDLT residential rates plus 5% additional-dwelling surcharge. Non-UK-resident purchasers are also subject to the additional 2% non-resident surcharge under FA 2003 Schedule 9A unless residence is established before completion under the SRT-aligned non-resident test.

Inbound IHT under LTR: Mrs Khoury is at year 1 of UK residence in 2026/27. LTR trigger comes at year 10 of UK residence (assuming continuous UK residence). Pre-LTR worldwide-asset IHT exposure starts only once 10-of-20 is crossed; meanwhile UK situs property is in UK IHT regardless under Schedule A1. The pre-trigger window for non-UK estate planning (settling non-UK assets into an excluded-property trust under the new IHTA 1984 s.48ZA before the 10-year clock crosses) is operationally precious. Pre-arrival planning lost: rebalancing the £4.2m portfolio to crystallise gains before arrival would have crystallised those gains outside UK CGT scope (non-UK-resident at the time). Post-arrival, the portfolio's accrued gains crystallise under UK CGT subject to FIG for the 4-year window only. Rebasing for her UK property purchases is unavailable: she does not hold those assets on 5 April 2017 (Schedule 11 condition 1 fails). For her Beirut portfolio, condition 5 (s.809B claim history 2017/18 to 2024/25) fails because she has never previously been UK-resident and never claimed remittance basis. Rebasing is unavailable on the foreign portfolio too.

Example two: Mr Olsson, returning Swedish business owner whose FIG gateway fails

Mr Olsson (Swedish citizen; UK-resident 2015/16 to 2021/22, a 7-tax-year stint; held London BTL bought 2018 plus Swedish investment portfolio acquired 2010; moved back to Stockholm 2022/23; sold Swedish portfolio for £350,000 gain in 2024/25 while Swedish-resident; returns to UK April 2026 for a new corporate role; sole shareholder and director of UK Ltd through which he holds the BTL).

SRT 2026/27 return year: full-time UK work from April 2026 satisfies the automatic UK test. Case 5 (starting full-time UK work) likely applies; pre-arrival part-year outside UK income tax scope. FIG eligibility check: s.845B(1)(b) requires non-UK-resident for each of the 10 tax years before 2026/27. Mr Olsson was UK-resident 2015/16 to 2021/22; within the 10-year lookback period (2016/17 to 2025/26 inclusive) he was UK-resident for 6 of the 10 years. FAILS the 10-of-prior-10 gateway. FIG NOT AVAILABLE. He enters as a standard arising-basis resident.

The s.10A symmetric trap: Mr Olsson was UK-resident 2015/16 to 2021/22 (7 of the 7 preceding tax years before 2022/23 departure, comfortably above the 4-of-7 gateway). His non-UK-residence period (2022/23 to 2025/26) is 4 complete tax years, within the "5 years or less" temporary-non-residence window. He returns April 2026 (the 2026/27 tax year). Temporary non-resident. The £350,000 Swedish-portfolio gain realised in 2024/25 is deemed to arise in 2026/27 under TCGA 1992 s.10A. UK CGT at standard rates applies in 2026/27 (post-30 October 2024 rates: 18% basic and 24% higher band for residential; 18% and 24% non-residential aligned from 30 October 2024). Estimated UK CGT at higher rate on £350,000 is around £84,000.

Sweden-side credit: Sweden taxed Mr Olsson on the £350,000 gain in 2024/25 (Swedish-resident at disposal). UK FTC via TIOPA 2010 s.18 may be available but only up to the lower of the two charges. The procedural mechanic for retrospective Swedish credit may be cumbersome and Swedish CGT (typically 30% on a different base) interacts unpredictably with the UK s.10A recapture; specialist UK and Swedish advice essential. UK BTL position: held throughout via UK Ltd. While Mr Olsson was non-UK-resident, the Ltd remained UK-incorporated, UK CT-resident, and within UK CT on rental profits and chargeable gains regardless of his residence. NRCGT did not apply to disposals by the Ltd (Ltd is UK-resident for CT purposes). NRL did not apply to the Ltd. On his return, his personal income from the Ltd (salary, dividends) becomes UK-IT-taxable arising basis from his residence start date.

IHT under LTR: Mr Olsson's UK-residence years count is 7 years (2015/16 to 2021/22) plus an emerging 2026/27 stint, totalling 8 of preceding 20 years (2007/08 to 2026/27). Below the LTR threshold of 10-of-20. Not LTR in 2026/27. Worldwide assets outside UK IHT scope. The UK BTL held via Ltd shares is in UK IHT through the Schedule A1 enveloped-residential look-through for UK residential property (effective 6 April 2017, unchanged by FA 2025). The historic deemed-domicile exit script (s.267 omitted from 6 April 2025 per FA 2025) is now irrelevant; the residence-based LTR test is the operative IHT trigger.

Verdict: Mr Olsson is materially worse off than expected. The £350,000 Swedish gain he assumed was permanently outside UK scope is now in UK scope via s.10A. The "I will be a new arrival and get FIG" assumption fails (the 10-of-prior-10 gateway is not met). Specialist pre-return planning could have advised holding the Swedish-portfolio sale until after 5 complete non-UK tax years (2027/28 onwards) to break the s.10A window, but he has already realised. Pragmatic options now: ensure Swedish-side credit is maximised; defer further non-UK disposals to post-2031/32 to avoid additional s.10A exposure on later realisations.

Example three: Mr Hayek and the FA 2025 Schedule 11 rebasing trap

Mr Hayek (Brazilian citizen; UK-resident 2018/19 to 2021/22, claimed remittance basis under ITA 2007 s.809B in each of those years; left UK 2022/23; returns October 2026 intending to settle; holds a £980,000 Lisbon flat acquired 2014, a London BTL acquired 2017 and a Hong Kong shares portfolio acquired 2010). In 2026 he hears about the "FA 2025 rebasing election to 5 April 2017 value" and assumes all three assets can be rebased.

FIG gateway check: Mr Hayek was UK-resident 2018/19 to 2021/22. Within the lookback period of 10 tax years before 2026/27 (2016/17 to 2025/26 inclusive) he was UK-resident for 4 of those 10 years. FAILS the 10-of-prior-10 gateway. FIG not available. He enters as arising-basis resident.

Rebasing election per FA 2025 Schedule 11 paragraph 1(1) walks five conditions for each asset.

  1. Asset held on 5 April 2017. London BTL acquired 2017 (verify exact contract and completion dates; purchases completing 6 April 2017 onwards fail). Lisbon flat acquired 2014 PASSES. Hong Kong portfolio acquired 2010 PASSES.
  2. Disposal on or after 6 April 2025. PASSES for any post-arrival disposal.
  3. Asset not situated in UK between 6 March 2024 and 5 April 2025. London BTL is UK situs throughout. FAILS condition 3 ABSOLUTELY for the London BTL. Lisbon flat is Portuguese situs; PASSES. Hong Kong portfolio (assuming HK-incorporated shares and HK-bank custody) is non-UK situs; PASSES.
  4. Individual not domiciled in UK before tax year 2025/26. Mr Hayek is Brazilian-domiciled-of-origin; PASSES (assuming no UK domicile-of-choice acquired, which is a high evidential bar).
  5. Claim made under ITA 2007 s.809B at least once in tax years 2017/18 to 2024/25. Mr Hayek claimed remittance basis 2018/19 to 2021/22, four claim years within the 2017/18 to 2024/25 window. PASSES.

Conclusion. The London BTL cannot be rebased under Schedule 11. Condition 3 is an absolute exclusion of UK situs assets; UK property is UK situs throughout. The misconception that "rebasing applies to all assets held by non-doms" is wrong for UK situs. The UK-property-specific rebasing dates are 5 April 2015 (residential acquired before that date) and 5 April 2019 (non-residential) under the separate NRCGT regime in TCGA 1992 s.1A and Schedule 1A. Mr Hayek's London BTL acquired 2017 is post-the 5 April 2015 residential default, so no NRCGT-side rebasing benefit either. His UK-property base cost is original acquisition cost.

The Lisbon flat may be rebased to 5 April 2017 value if all five conditions are met. Acquisition cost 2014 versus 5 April 2017 value: if the flat appreciated 2014 to 2017, rebasing upsteps base cost and reduces UK CGT on a later disposal. The election is per-disposal and irrevocable under Schedule 11 paragraph 3. The Hong Kong portfolio may be rebased similarly (all five conditions met assuming HK situs holds). Default is rebasing for qualifying assets per paragraph 3; an opt-out election is available where 5 April 2017 value is lower than original cost (uncommon).

Operational lesson: the inbound non-dom needs a per-asset rebasing analysis before any post-arrival disposals. UK situs assets are out of scope absolutely. Non-UK situs assets need the 5-condition test. Some assets benefit, others do not.

NRCGT on any pre-arrival UK property disposal

NRCGT under TCGA 1992 s.1A applies to non-resident disposals of UK land regardless of the disposer's intention to arrive in the UK shortly thereafter. The 60-day NRCGT return is mandatory on every disposal of UK land by a non-UK-resident, including disposals of indirect interests in UK property-rich entities under Schedule 1A Part 4 (the 75% UK land-value test plus 25% holder-stake test). The 60-day clock runs from completion (not exchange).

Residential rates from 30 October 2024 are 18% (basic) and 24% (higher band). Non-residential rates are 18% and 24% aligned with residential from the same date. The CGT annual exempt amount is £3,000 for individuals retaining a UK personal allowance under ITA 2007 s.56; nil for non-resident companies (which fall within CT on UK property gains instead, post-FA 2019 Schedule 5 reforms).

Schedule 4AA gives default rebasing for UK land: 5 April 2015 for residential property acquired before that date; 5 April 2019 for non-residential interests and indirect-disposal interests acquired before that date. Default-rebasing election is opt-out (most disposers benefit because UK property typically appreciated 2010 to 2015 to 2019); the alternative is to use original acquisition cost or to time-apportion the gain over the holding period. A pre-arrival UK property disposal during continuing non-residence requires this analysis even if the inbound move is days away.

NRL withholding turn-off mechanics on arrival

The Non-Resident Landlord scheme under FA 1995 Schedule 23 and SI 1995/2902 operates whenever the landlord is non-UK-resident. The mechanism is statutory: letting agents (or tenants paying rent directly) withhold 20% basic rate from rents and account to HMRC on the NRLY annual return, with monthly NRLY-CT80 payments to HMRC. The landlord can apply (via NRL1 for individuals, NRL2 for letting agents, NRL3 for trustees) for gross-payment approval; HMRC grants approval where the landlord has a clean UK tax compliance record and an SA account.

On arrival, once SRT makes the landlord UK-resident, the NRL withholding obligation falls away from the residence start date. The operational steps are: (a) notify the letting agent and any tenants paying directly in writing of the residence change; (b) complete NRL6 close-out paperwork as needed (the agent or tenant cancels their NRLY registration; HMRC issues a close-out confirmation); (c) the agent or tenant stops the 20% withholding from the residence start date; (d) the landlord self-assesses UK rental income on SA100 plus SA105 (UK property pages) annually going forward. UK rental income remains UK-taxable under ITTOIA 2005 Part 3 (individuals) or CTA 2009 Part 4 (companies) regardless of NRL status; the NRL is a withholding mechanism, not a chargeable basis.

The IHT Long-Term Resident clock

IHTA 1984 ss.6A to 6C (FA 2025 architecture, in force from 6 April 2025) defines a Long-Term UK Resident as an individual UK-resident in 10 of the preceding 20 tax years. Once LTR, the individual's worldwide assets are within UK IHT. The historic deemed-domicile test at IHTA 1984 s.267 was omitted by FA 2025 from 6 April 2025; domicile is no longer the operative IHT trigger.

The under-20-years-old variation in s.6B varies the residence-year count for arrivers aged under 20. Specialist verification at write is required for any borderline minor-arrival case.

The LTR election framework in ss.267ZC to 267ZF allows certain elections (typically by a non-LTR spouse of an LTR individual to opt into LTR for spouse-exemption purposes; or by an LTR individual to elect into long-term-resident treatment earlier). The mechanics are intricate and the elections are irrevocable in their operative window.

UK situs property remains in UK IHT regardless of LTR status under IHTA 1984 Schedule A1 (enveloped-residential look-through, effective 6 April 2017, unchanged by FA 2025). A UK BTL held through a UK or overseas company is in UK IHT through the Schedule A1 look-through regardless of the shareholder's LTR status. The pre-LTR window (years 1 to 9 of UK residence for a first-time arrival) is the precious estate-planning period for non-UK assets; once LTR triggers, settling non-UK assets into trust loses excluded-property status under the rewritten s.48ZA test.

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Example four: Sir Henderson, US-citizen HNW arrival with a 10-year LTR clock

Sir Henderson (US citizen, UK-resident on arrival; arrives March 2026 [tax year 2025/26] for retirement; HNW estate of $42m worldwide: $6m UK residential property [London townhouse purchased 2018 via UK Ltd, held to date], $28m US-based investment portfolio, $4m US business interests, $4m UK-based investment trust).

UK arrival 2025/26: Sir Henderson is UK-resident from arrival. FIG gateway check: never UK-resident before; 10-of-prior-10 PASSES; aged over 10; ELIGIBLE for FIG 2025/26 to 2028/29 (4 tax years). LTR clock: at end of 2025/26, Sir Henderson has been UK-resident in 1 of preceding 20 tax years. NOT LTR. Worldwide assets outside UK IHT (subject to UK situs property treatment below). LTR trigger timing: if Sir Henderson remains continuously UK-resident, LTR trigger comes at end of 2034/35 (UK-resident in 10 of the preceding 20 tax years: 2025/26 to 2034/35 inclusive). At that point his worldwide $42m estate enters UK IHT (assuming survival to that date, NRB and RNRB unchanged, no spouse-exemption planning).

UK situs property remains in UK IHT regardless. The UK Ltd holding the London townhouse is subject to Schedule A1 enveloped-residential look-through; the Ltd's London townhouse is in UK IHT regardless of LTR status. His UK investment trust ($4m, UK situs) is in UK IHT regardless. So $10m of UK-situs property is in UK IHT scope from day 1 of arrival. Pre-LTR window for non-UK estate planning: approximately 9 years of non-LTR status. Settling non-UK assets into an excluded-property trust under the new IHTA 1984 s.48ZA before the LTR trigger date is critical; assets settled while the settlor is non-LTR are excluded property; assets settled after LTR trigger lose excluded-property status. Specialist private-client team essential.

The s.6B under-20 variation does not apply (Sir Henderson is over 20). The ss.267ZC to 267ZF election framework may give options once the LTR trigger approaches; elections are typically irrevocable. TRF unavailable: Sir Henderson has never been UK-resident pre-2025/26, so no remittance-basis pool and no TRF designation eligibility. (TRF is for the cleanup of historic remittance-basis users only.)

Verdict: claim FIG for the 4-year window 2025/26 to 2028/29, maximising income and gains realisations from his $28m US portfolio and $4m US business interests during the window. Post-window, arising-basis on worldwide income and gains. Pre-LTR estate-planning window (years 1 to 9 of UK residence) is precious for non-UK asset trust settlement; UK situs property is in UK IHT regardless from day 1, with no planning option beyond standard NRB, RNRB and spouse exemption.

The Temporary Repatriation Facility for returning UK non-doms

FA 2025 s.41 and Schedule 10 introduce the Temporary Repatriation Facility for individuals who previously claimed remittance basis pre-6 April 2025. The TRF designation allows previously unremitted foreign income and gains to be designated for UK taxation at concessionary rates: 12% for designation in 2025/26 or 2026/27, 15% for designation in 2027/28. The window closes 5 April 2028.

The designation deadline per Schedule 10 paragraph 8(1) is 31 January 12 months after the end of the relevant tax year. For 2025/26 designation, the deadline is 31 January 2028. For 2026/27, 31 January 2029. For 2027/28, 31 January 2030. The TRF is irrevocable once designated; designated funds are crystallised as clean capital and may be remitted to the UK without further UK tax exposure.

The TRF is for cleanup, not for cashflow. A returning UK non-dom with a substantial accumulated unremitted-pool (£500,000-plus typically) facing a UK-resident retirement should model the TRF designation against the alternative of staged remittance over future UK-tax years at marginal rates. Specialist tax counsel and personal modelling are essential because the optimal designation strategy depends on the size of the pool, the timing of expected remittance, the future UK marginal-rate position and the post-arrival income mix.

A first-time arrival without a prior UK history has no remittance-basis pool and no TRF eligibility. The TRF is solely a transitional facility for the historic non-dom population.

The s.10A symmetric trap for returning UK nationals

TCGA 1992 s.10A is the temporary-non-residence rule. It catches UK nationals (or UK-resident individuals more broadly) who leave the UK, sell non-UK assets while non-resident, and return within 5 years. The mechanism is symmetric: the same rule that we cover at length in the outbound page (where it crystallises a return-year recapture for emigrants) operates on the inbound side for returnees who sold non-UK assets during their non-residence.

The gateway under s.10A is twofold. First, the individual must have been UK-resident in 4 or more of the 7 tax years before departure. Second, the period of non-UK-residence at the time of return must be 5 years or less. Where both gateway conditions are met, the gains realised on non-UK assets during non-residence are deemed to arise in the year of return and chargeable to UK CGT in that year. ITA 2007 s.812 applies the same architecture to certain income (dividend and pension lump-sum income arising during the temporary-non-residence window).

The trap interacts with NRCGT on UK land. NRCGT under TCGA 1992 s.1A applies independently of s.10A: a non-resident's disposal of UK land triggers NRCGT at the time of disposal regardless of whether s.10A also applies. The two regimes do not double-count the same gain; s.10A primarily catches non-UK situs gains realised during non-residence, while NRCGT catches UK land disposals. A returning UK national who sold both a UK BTL (caught by NRCGT at the time) and a non-UK share portfolio (caught by s.10A in the return year) faces UK CGT on the UK BTL gain at the disposal date and UK CGT on the share-portfolio gain at the return-year date.

For the inbound returnee, the planning lesson is straightforward but stark. If you left the UK and have realised non-UK gains during non-residence, defer your return until at least 5 complete tax years of non-UK residence have elapsed (year 6 onwards). If you cannot defer, the gains will crystallise in the return year. Foreign-side tax credit via TIOPA 2010 s.18 is available but only up to the lower of the UK and foreign tax; the practical recovery can be procedurally cumbersome.

Source-state DTA framing for the arrival year

Where you remain dual-resident under SRT (UK) and source-state domestic law for part of the arrival year, the OECD Model Article 4 tie-breaker cascade applies. Tie-breaker tests run in this order: (a) permanent home; (b) centre of vital interests; (c) habitual abode; (d) nationality; (e) mutual agreement. The tie-breaker affects treaty allocation only, not domestic-law UK residence under the SRT. UK statutory residence remains determined by FA 2013 Schedule 45 regardless of the treaty outcome.

OECD Model Article 6 (immovable property income) is allocated to the source state; UK property income generated by a UK BTL held during arrival year is UK-taxable as source income regardless of the tie-breaker outcome. Article 13 (gains on immovable property) is similarly allocated to the source state; UK property gains during the arrival year fall to UK CGT or NRCGT depending on residence at the disposal date. Article 23 (elimination of double taxation) sets out the FTC framework. The UK domestic FTC mechanism in TIOPA 2010 s.18 mirrors most OECD treaty Article 23 mechanics: entitlement to credit for foreign tax reduces UK tax by the amount of the credit, capped at the lower of UK and foreign tax.

For specific bilateral positions on UK-India, UK-Isle of Man, UK-Spain, UK-US, UK-Lebanon, UK-Sweden and other key inbound jurisdictions, see our country-specific DTA pages. The general framing here is structural; the specific clauses, timings and ratification status vary materially by treaty and require verification against the live treaty text at consultation date.

Frequently asked questions

The FAQ list above covers what the two operative inbound entry points are (FIG and LTR), how SRT applies in the arrival year, the split-year Cases 4 to 8, the 10-of-prior-10 gateway for FIG with two worked contrasts, the lost-allowance trade-off, the FIG claim deadline, the UK-property rebasing trap under Schedule 11 condition 3, NRCGT on pre-arrival UK property disposals, the LTR trigger and pre-LTR estate-planning window, the s.10A symmetric trap for returning UK nationals, the TRF for returning non-doms with pre-2025 unremitted pools, the source-state DTA framing for the arrival year, the NRL withholding turn-off mechanics, and the inbound trust-settlement position under the rewritten s.48ZA. For the outbound mirror, see our are you leaving the UK permanently page. For the IHT-residence side, see our IHT residence test for non-resident UK property page. For NRCGT mechanics, see our non-resident CGT on UK property page.

Next step

If you are planning a move to the UK and you hold (or are about to acquire) UK property, the SRT analysis for your arrival year, the FIG eligibility test against the 10-of-prior-10 gateway, the IHT LTR clock for your worldwide estate, the UK-property rebasing position under Schedule 11, and (for returning UK nationals or non-doms) the s.10A or TRF positions need to be planned together in the months before arrival, not after. Inbound advice that pre-dates FA 2025 (anchored on remittance basis, deemed domicile, or "non-dom" framing) is obsolete on the IHT and non-dom sides. Contact us via the form below to discuss your specific position.