The Historic Abolition of the Remittance Basis
After decades of controversy and political debate, the UK government has announced the abolition of the Non-Dom status effective from 6 April 2025.
This move ends the long-standing remittance basis, which allowed individuals domiciled abroad to pay tax only on income and gains brought into the UK. Going forward, all UK residents will be subject to taxation on worldwide income and gains, fundamentally changing the landscape for international high-net-worth individuals.
The reform aims to align the UK with international norms and create a simpler, fairer tax system. By removing domicile as the basis for taxation, policymakers hope to eliminate loopholes that have allowed the ultra-wealthy to significantly reduce their UK tax liabilities. However, many experts anticipate significant shifts in residency patterns and investment flows.
For individuals affected by these changes, understanding the practical implications and transitional relief options will be crucial in planning for the coming years. Those accustomed to remittance-based taxation must now reassess their financial structures and compliance obligations.
The Introduction of the Four-Year Foreign Income and Gains Regime
To ease the transition, the UK will introduce a new Four-Year Foreign Income and Gains (FIG) regime. This special relief will be available to individuals who become UK tax residents after spending at least ten consecutive years abroad. Under this regime, qualifying individuals can benefit from an exemption on foreign income and gains for the first four years of UK tax residency.
Unlike the remittance basis, this relief does not require funds to remain offshore. Income and gains can be brought into the UK without triggering an immediate tax charge during the four-year period. However, this benefit is strictly time-limited, after which worldwide taxation applies in full.
Prospective residents and returning expatriates should carefully assess whether they meet the qualifying criteria and understand the timeframes involved. Claiming the relief requires proactive planning to maximize its value.
Transitional Repatriation Facilities for Existing Non-Doms
For those already benefiting from the remittance basis, the UK government is offering a Transitional Repatriation Facility (TRF). This measure allows non-doms to bring previously untaxed foreign income and gains into the UK at reduced tax rates of 12% in the 2025/26 and 2026/27 tax years, rising to 15% in 2027/28.
The TRF is designed to encourage individuals to repatriate offshore wealth during a defined window while securing tax revenue for HMRC. While the rates are considerably lower than standard income tax and capital gains tax rates, they still represent a significant liability for many long-term non-doms.
Taxpayers considering the TRF should consult advisors promptly, as utilizing this facility requires timely elections and robust documentation. The opportunity to regularize historic income and gains under favorable terms may prove attractive to many affected individuals.
Capital Gains Tax Rebasing for Overseas Assets
Another key transitional measure is the rebasing of foreign-held assets for capital gains tax purposes. Individuals who have claimed the remittance basis will be able to rebase the value of their personally held foreign assets to 5 April 2019, potentially reducing future capital gains tax liabilities.
This relief ensures that gains accrued prior to the cut-off date are effectively ring-fenced from UK taxation, providing some mitigation for long-term investors. However, any gains arising after the rebasing date will be fully subject to
UK capital gains tax once the new regime commences. Understanding which assets qualify for rebasing and how to establish their market value as of April 2019 will be vital. Clear records and valuation evidence will support compliant tax reporting in subsequent years.
The End of Trust Protections
Perhaps the most significant change for wealth structuring is the end of trust protections previously enjoyed by non-doms. Under the old rules, settlor-interested trusts often sheltered foreign income and gains from UK taxation unless distributions were made.
From April 2025, these protections are being removed. Income and gains arising in such trusts will now be attributed directly to the settlor if they are UK tax residents. This development will require a wholesale review of trust structures and their tax efficiency going forward.
Advisors recommend conducting a full trust audit to identify exposures and consider restructuring options. For many, this change represents a profound shift in the viability of offshore trust arrangements.
Inheritance Tax Shifts to a Residence-Based System
In addition to income and gains taxation, the reforms also transform the scope of UK Inheritance Tax (IHT). Previously, IHT was primarily based on domicile, with non-doms only exposed on UK assets.
Under the new rules, individuals who have been UK tax resident for ten out of the previous twenty years will become liable for IHT on their worldwide assets. Notably, this exposure continues for up to ten years after ceasing UK
residency, significantly extending potential liabilities.
This development underscores the need for robust succession and estate planning. Those with significant offshore wealth must reevaluate their IHT strategies and consider potential mitigations such as gifting, trusts, or relocation.
The Reaction Among High-Net-Worth Individuals
The policy has been met with strong reactions among wealthy residents and their advisors. Many have expressed concerns about the potential exodus of international investors and entrepreneurs, who may choose to relocate to jurisdictions offering more favorable tax regimes.
Reports from financial media suggest that destinations such as Italy, Switzerland, the UAE, and Portugal are already seeing heightened interest from UK-based non-doms exploring relocation options. This movement could have material impacts on sectors such as London real estate and private banking.
Nonetheless, the government maintains that the reforms create a more equitable system while securing vital tax revenues. The long-term economic consequences remain to be seen.
Implications for UK Investment and Economic Growth
Proponents of the changes argue that ending the remittance basis will increase tax revenues and fund essential public services. Critics, however, fear that the reforms could stifle inward investment and innovation.
In particular, sectors heavily reliant on international capital and expertise may face challenges if high-net-worth individuals choose to depart. The policy therefore represents a complex trade-off between fairness and competitiveness.
Business leaders and trade associations continue to lobby for transitional arrangements and potential carve-outs to mitigate adverse impacts on the UK’s attractiveness as a hub for global talent.
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