Remittance Basis Tax Insights for Non-Domiciled Individuals: What Ended on 6 April 2025, What Replaced It, and the FIG / TRF / Rebasing Architecture That Now Governs UK Property Investors with Foreign Income

The remittance basis ended on 6 April 2025 under Finance Act 2025 s.40 and Schedule 9. From tax year 2025-26 onwards, no individual can make a fresh claim under ITA 2007 s.809B. The 200-year UK income-tax concession that allowed foreign-domiciled UK residents to keep foreign-source income and gains outside UK tax until remitted has been closed.

This page is the historical-context hub for the post-6-April-2025 non-dom architecture. It explains what was lost, what replaced it, and routes the reader to the four deep-dive pages on the operational mechanics. It is written for non-domiciled individuals running compliance decisions on legacy claims, advisers handling Temporary Repatriation Facility designations for legacy clients, expat landlords considering a UK return, new arrivals weighing the FIG regime against arising basis from day one, and trust beneficiaries and settlors with pre-FA-2025 structures.

The 6 April 2025 cliff in one read

The reform is a cliff, not a gradual wind-down. From 6 April 2025 four things changed at once:

• Income tax + CGT. The remittance basis disappeared. UK residents are now taxed on a worldwide arising basis, subject to the new 4-year FIG exemption for qualifying new arrivals.
• IHT. The historic deemed-dom 15-of-20 test was retired. A new residence-based Long-Term Resident test under IHTA 1984 ss.6A-6C determines IHT exposure on worldwide-situs assets.
• Trust attribution. Excluded-property trust treatment under IHTA 1984 s.48 was modified by new s.48ZA. Pre-existing trusts created before the settlor reached LTR status retain their excluded-property status; trusts created after that point do not.
• Legacy cohort. A three-year Temporary Repatriation Facility under FA 2025 s.41 and Schedule 10 allows pre-2025-26 unremitted amounts to be designated at fixed rates and brought into the UK without the normal remittance charge.

The operative law is FA 2025, not the Spring Budget 2024 political announcement. Royal Assent fell on 20 March 2025. Several competitor commentaries still describe the position as an announced reform; that is wrong. The reform is on the statute book and is in force.

What the remittance basis was, in brief

The remittance basis under ITA 2007 ss.809A-809Z10 was a per-year claim. A foreign-domiciled UK resident could elect, year by year, to be taxed in the UK only on foreign income and gains actually remitted to the UK (broadly, brought to or used in the UK directly or indirectly). Unremitted foreign amounts stayed outside UK tax. The price of the claim escalated with UK-residence tenure: a remittance basis charge of £30,000, £60,000, or £90,000 became payable from various tenure thresholds. Personal allowance and CGT annual exempt amount were lost in any claim year.

UK-source income was never within scope. The concession applied only to foreign-source income and gains. UK rental income from UK property was, and remains, taxed on the arising basis regardless of domicile. Competitor pages frequently imply otherwise; that is a long-standing drift.

The concession had narrowed materially through the 2008 reforms (introduction of the remittance basis charge), the 2017 reforms (deemed domicile after 15 of 20 tax years; protected-trust architecture; rebasing election for the 2017 cohort), and finally the FA 2025 abolition.

FIG: the replacement for new arrivals

The new regime for qualifying new residents is the Foreign Income and Gains (FIG) regime under ITTOIA 2005 ss.845A-845J, inserted by FA 2025 s.37 and Schedule 8. Headline mechanics:

• Eligibility. The individual must have been non-UK-resident for each of the 10 tax years immediately before the first qualifying year. The gateway is 10 years of prior non-residence, not 7 years (a frequent competitor error).
• Window. 4 tax years of full foreign-income-and-gains exemption from the first qualifying year. The 4-year window runs sequentially from the first year of UK residence after the 10-year gateway is met.
• Per-year claim. The exemption is not automatic. A claim must be made on the self-assessment return for each year in which the relief is sought. Missing a claim forfeits that year's relief.
• Allowance cost. In any year a FIG claim is made, the individual loses personal allowance, dividend allowance, and CGT annual exempt amount. The arithmetic on whether to claim depends on the size of the foreign income and gains pool relative to these allowances.
• Deadline. The claim must be made within 12 months of 31 January following the end of the relevant tax year.

FIG is not a perpetual concession. After the 4-year window closes, the individual is on the worldwide arising basis with no further foreign-income relief, subject to the temporary-non-residence rules under TCGA 1992 s.10A if they later leave the UK.

For the operational deep-dive on FIG, including worked examples for property investors, see the FIG regime for property investors page. For the post-window planning, see the FIG year-5 cliff page.

TRF: the legacy-cohort wind-down

The Temporary Repatriation Facility under FA 2025 Schedule 10 is a three-year window allowing the pre-2025-26 remittance-basis cohort to bring previously-unremitted foreign capital into the UK at fixed designation rates:

• 2025-26 designations: 12%.
• 2026-27 designations: 12%.
• 2027-28 designations: 15%.
• Window closes: 5 April 2028. No designations are possible from 6 April 2028 onwards.

Three designation scenarios sit in Sch 10 para 2:

1. Sch 10 para 2(2): pre-window unremitted accumulation. Amounts that remain unremitted at the date of designation under the historic remittance-basis tracking. The cohort and source-tracing discipline is essential to identifying eligible amounts.
2. Sch 10 para 2(5): in-window remittance. Amounts remitted to the UK during the 2025-26 to 2027-28 designation window can be designated at the relevant year's rate.
3. Sch 10 para 2(8): residual pre-6-April-2025 offshore capital. Non-income, non-gain offshore capital held immediately before 6 April 2025 can be designated under this scenario.

The designation deadline is 12 months from 31 January following the end of the relevant tax year. Late designations are not accepted; the rate-locked window is the operative discipline.

TRF is for the legacy cohort only. A 2025-26 new arrival does not use TRF; they use FIG. The two regimes are mutually exclusive in any given tax year by reference to the individual's historic status.

For the scenario-by-scenario operational deep-dive, see the TRF qualifying overseas capital page.

CGT rebasing: the narrow Sch 11 election

FA 2025 s.42 and Schedule 11 introduced an election to rebase non-UK assets to their 5 April 2017 market value. The election is available only to individuals who satisfy two cumulative conditions:

• They claimed the remittance basis in at least one tax year between 2017-18 and 2024-25.
• They were neither UK-domiciled nor deemed-domiciled on 5 April 2017.

Both conditions must be met. Most departing UK landlords fail one of them: they either never claimed the remittance basis (so condition one fails) or they had reached deemed-dom status by 5 April 2017 (so condition two fails). The election is therefore much narrower than the headline "rebasing relief" framing in some commentaries suggests.

The election is made disposal by disposal. For a qualifying individual, the effect is to substitute the 5 April 2017 market value for the original base cost on the elected disposal. This typically reduces the chargeable gain on a long-held foreign asset where the 2017 value was meaningfully above original cost.

For the eligibility analysis and worked examples, see the FA 2025 Sch 11 narrow eligibility page.

IHT: the new LTR architecture

The historic deemed-dom 15-of-20 test for IHT has been retired. The new test under IHTA 1984 ss.6A-6C is the Long-Term Resident (LTR) test. Headline mechanics:

• Standard rule (s.6A): an individual is long-term UK resident, and therefore within IHT on worldwide-situs assets, if they have been UK-resident for at least 10 of the preceding 20 tax years.
• Young-person variation (s.6B): for individuals under 20, the test adjusts to reflect the shorter possible residence history.
• Departure tail (s.6C): a person who has been LTR retains LTR status for a tail period after ceasing UK residence, with the length of the tail depending on the residence history.

The reform is residence-based, not domicile-based. A high-net-worth arrival with no UK domicile of origin but who reaches 10 years of UK residence comes within worldwide IHT exposure. Conversely, an individual with a UK domicile of origin who has lived abroad for many years can fall outside the LTR test if their UK-residence count is below the threshold.

Trust attribution is governed by IHTA 1984 s.48ZA, inserted by FA 2025. Trusts created before the settlor reached LTR status retain excluded-property treatment for non-UK situs assets. Trusts created after LTR status was reached lose that treatment, with full settlor-attribution mechanics applying. The transitional rules around partial creation dates and settled property top-ups are the most technically complex part of the reform.

What does this mean for UK property investors?

Four investor-specific points stand out.

UK rental income was always arising-basis

The most common drift in popular non-dom commentary is to imply the remittance basis somehow covered UK-source income. It did not. A non-dom landlord with UK property always paid UK income tax on UK rental income, on the arising basis, regardless of where the rental cash was paid or held. The abolition therefore changes nothing for the UK-source income side. It changes everything for foreign-source rental income from overseas property held personally.

Foreign-source rental income is now arising-basis from year 5

A UK-resident new arrival with overseas property holds a 4-year FIG window during which foreign rental income is exempt (if a claim is made and the personal allowance / CGT AEA cost is accepted). From year 5 onwards, the foreign rental income is taxed on the UK arising basis with foreign tax credit relief under the relevant double taxation agreement. The Year 5 cliff is a planning point for any landlord with material overseas property.

NRCGT continuity for overseas-resident UK-property owners

Non-resident CGT on UK land under TCGA 1992 Sch 4ZZB is unchanged. Overseas-resident owners of UK property pay UK CGT on disposal regardless of domicile, and report via the 60-day NRCGT return. The FA 2025 reform does not modify the NRCGT framework.

The 10-year LTR clock starts on first UK-resident year

For a non-dom approaching the LTR threshold, the trust-structure review is essential. Excluded-property trusts created in the run-up to year 10 of UK residence retain protection; those created after the threshold is crossed do not. The window for setting up legacy-structure-equivalent protection is narrow and the discipline is to act well before the LTR clock ticks over.

What happened to the remittance basis charge?

The £30,000 / £60,000 / £90,000 remittance basis charge was payable only by individuals making a remittance basis claim. From 6 April 2025, no claim can be made under ITA 2007 s.809B, so no charge arises. The historic charge architecture is closed.

Pre-2025-26 charge payments stand. There is no rebate mechanism. The charge was the price of the relief in each prior year; it remains so.

What is the residual operation of domicile?

Domicile has not been abolished as a legal concept. It is a common-law concept rooted in private international law and continues to operate in three contexts:

• Trust attribution under s.48ZA transitional architecture. The pre-LTR-onset / post-LTR-onset boundary turns on the settlor's status at the date of trust creation, which references domicile in some transitional fact patterns.
• Private international law. Cross-border succession, family law, conflict of laws all use domicile.
• Certain double taxation agreements. Treaties that retain domicile language in the residence article continue to operate on that basis.

The headline framing is that domicile no longer drives the mainstream UK tax position. The nuance is that it retains residual operation for these specific contexts. Competitor pages that state "domicile no longer matters" are oversimplifying.

The three things a non-dom property investor should do now

1. Run the SRT and LTR clock. Confirm current UK tax residence under FA 2013 Schedule 45 for the current tax year, and count UK-resident years over the preceding 20 to identify position against the LTR threshold. For the SRT cascade walk-through and the LTR mechanics, see the residency and domicile primer.
2. Model FIG year-by-year for the 4-year window. If a new arrival from 2025-26, model the FIG-vs-arising-basis choice for each year of the window. The arithmetic depends on the size of foreign income and gains relative to personal allowance and CGT annual exempt amount.
3. Model TRF designation choices for the legacy cohort. If a legacy non-dom with pre-2025 unremitted balances, model the TRF Scenario A / B / C choice against the rate ramp (12% / 12% / 15%) and the 5 April 2028 closing window. Specialist source-tracing of historic remittance-basis-tracked amounts is foundational to the designation.

The reform architecture is technically dense but the decisions a typical non-dom UK-property investor must make are bounded: residence and LTR position; FIG claim per year; TRF designation per scenario; trust-structure review before the LTR clock ticks over. Each decision routes to a specific deep-dive page or a specialist advisory engagement. Use the form at the foot of the page to start.