Is the UK inheritance tax tail after leaving really ten years?

Only for someone who was UK resident for all 20 of the previous tax years. The tail is a sliding scale set out in HMRC’s inheritance tax manual: 13 prior resident years or fewer gives a 3-year tail, 14 gives 4, 15 gives 5, and so on, up to 20 years of residence giving the full 10-year tail. Long-term resident status itself attaches at 10 of the previous 20 tax years, and resets after 10 consecutive years of non-residence.

How long is left on the 12% Temporary Repatriation Facility rate?

The 12% rate applies for 2025/26 and 2026/27, so roughly twenty months remain as at July 2026. It rises to 15% for 2027/28, and the facility closes permanently on 5 April 2028, after which remittances of pre-6 April 2025 foreign income and gains face up to 45%. The funds do not have to physically move during the window — designation on the return is the act.

Is claiming the 4-year FIG regime always worthwhile?

No. Making a foreign income claim, a foreign gain claim or an Overseas Workday Relief election for a tax year forfeits the income tax personal allowance and the CGT annual exempt amount for that year, along with Married Couple’s, Marriage and Blind Person’s Allowances and the ability to claim foreign income and capital losses. The forfeiture is total even if you claim for only one of the three. For modest foreign income the regime loses money.

Which non-dom style regimes are still open?

Ireland (remittance basis, no time limit), Malta (remittance basis with a EUR 5,000 minimum tax where foreign income is at least EUR 35,000), Cyprus (17 of 20 years, extendable to 27 at EUR 250,000 per five-year period from 2026), Greece (EUR 100,000 flat for up to 15 years, but with no credit for foreign tax), and Italy (EUR 300,000 for those transferring residence from 1 January 2026, up from EUR 200,000 and originally EUR 100,000).

The end of non-dom

On 6 April 2025 the United Kingdom removed domicile from its tax code. Two hundred years of domicile-based taxation, and the remittance basis that went with it, were replaced by a four-year residence-based regime and a residence-based inheritance tax.

Two numbers matter more than the rest. The Temporary Repatriation Facility charges 12% until 5 April 2027 — roughly twenty months of that rate remain as at July 2026 — before stepping to 15% and closing entirely on 5 April 2028. And the inheritance tax tail after departure is not a flat ten years. It is a sliding scale, and for most people it is shorter than they have been told.

The 4-year FIG regime

A qualifying new arrival pays no UK tax on foreign income and gains arising in their first four years of UK residence — and, unlike the old remittance basis, can bring the money into the UK freely. No remittance discipline, no offshore mixed funds, no clean capital analysis.

The gate is hard: 10 consecutive tax years of non-UK residence immediately before arrival. A single UK tax-resident year in the preceding decade disqualifies you entirely. There is no partial relief and no discretion.

The four years run from the start of UK residence and cannot be extended or paused. They run whether or not you claim. A year abroad in the middle does not stop the clock.

The price of claiming

This is the part that is not on the front page. Making a foreign income claim, a foreign gain claim, or an Overseas Workday Relief election for a tax year forfeits, for that year:

the income tax personal allowance
the CGT annual exempt amount
Married Couple's Allowance, Marriage Allowance and Blind Person's Allowance
the ability to claim foreign income and capital losses

The forfeiture is total even if you claim for only one of the three. For modest foreign income, claiming FIG loses money. Model it; do not assume it.

The Temporary Repatriation Facility

The TRF is an amnesty on the old stock of unremitted foreign income and gains, not on the new flow. Former remittance-basis users designate pre-6 April 2025 FIG on their return and pay:

Tax year	TRF rate
2025/26	12%
2026/27	12%
2027/28	15%
From 6 April 2028	Closed — up to 45% on remittance

The funds do not need to physically move during the window. Designation is the act.

Against a charge of up to 45% that would otherwise apply on remittance, 12% is the largest time-sensitive number in UK personal tax at present, and the window is roughly twenty months wide. Waiting until 2027/28 costs three percentage points. Waiting past 5 April 2028 costs the facility.

The IHT tail is a sliding scale, not ten years

From 6 April 2025 UK inheritance tax is residence-based. You are a long-term UK resident, and therefore within IHT on worldwide assets, if you were UK resident for at least 10 of the previous 20 tax years. The Statutory Residence Test, not domicile, decides.

The critical point, and the one most often stated wrongly: the tail after departure scales with how long you were resident. HMRC's inheritance tax manual sets it out:

Tax years of UK residence in the prior 20	IHT tail after departure
10–13	3 years
14	4 years
15	5 years
16	6 years
17	7 years
18	8 years
19	9 years
20	10 years

Only a person with the full twenty years of prior residence carries the ten-year tail. Someone with twelve years carries three. Stating "ten years" flatly is wrong for most clients, and it is wrong in the direction that makes departure look worse than it is — convenient for anyone selling a reason to stay, and expensive for anyone making a decision on it.

Long-term resident status resets after 10 consecutive years of non-residence.

What people do miss is the tail's existence at all. Leaving the UK does not remove worldwide assets from IHT. Emigration plans built around income tax alone routinely ignore a 40% charge on the global estate for a period of years after departure.

Where the concept still lives

The UK's exit leaves five regimes. They are now the whole market.

Ireland is the most durable by duration: the remittance basis applies to resident non-domiciled individuals with no statutory time limit. Foreign income and gains left outside Ireland are outside the Irish charge; Irish-source income is fully taxable. Ireland's high headline rates make the remittance discipline unusually consequential.

Malta taxes foreign income only on remittance and exempts foreign capital gains entirely, even if remitted. A minimum annual tax of EUR 5,000 applies to ordinarily-resident non-domiciled individuals with foreign income of at least EUR 35,000 (Act VII of 2018, from year of assessment 2019), unless they hold special tax status. The Global Residence Programme charges 15% on remitted foreign income with a EUR 15,000 minimum instead.

Cyprus survived its own 2026 overhaul and improved. The reform passed on 22 December 2025, was gazetted on 31 December 2025 and came into force on 1 January 2026, leaving the non-dom regime intact: a resident not domiciled in Cyprus is exempt from Special Defence Contribution on dividends and interest until they have been resident for 17 of the last 20 years. New from 2026, a deemed-domiciled individual whose domicile of origin is outside Cyprus can extend the exemption for up to two further five-year periods at EUR 250,000 upfront per period — a maximum of 27 years. Also from 1 January 2026, rental income is out of SDC, and the SDC rate on dividends for domiciled residents fell from 17% to 5%.

Greece offers art. 5A: EUR 100,000 a year flat on all foreign-source income for up to 15 years, requiring non-residence for 7 of the 8 prior years and at least EUR 500,000 invested in Greek real estate, businesses or securities within three years. Family members are EUR 20,000 each. The trap is that foreign tax paid on income inside the regime is not creditable in Greece. For anyone with withheld-at-source foreign income, the EUR 100,000 is an addition to foreign withholding rather than a substitute for it. Model it on top, not instead.

Italy has repriced twice in eighteen months. The art. 24-bis TUIR substitute tax on foreign income was EUR 100,000 from 2017, EUR 200,000 by Decree-Law 113/2024 for those transferring residence after August 2024, and EUR 300,000 under the 2026 Budget Law (Legge 30 dicembre 2025, n. 199) for those transferring from 1 January 2026. The family-member add-on went from EUR 25,000 to EUR 50,000. Earlier entrants have been grandfathered at the rate in force when they entered, each time. The regime still runs a maximum of 15 years and still excludes foreign assets from Italian inheritance and gift tax.

What could move

Italy has tripled its price in eighteen months. Grandfathering has been honoured on each occasion, but the direction of travel is unambiguous. Anyone modelling a 15-year Italian regime should model further increases for new entrants.
Cyprus's EUR 250,000 extension is legislated, in force, and untested. No one has yet run the full 17-plus-5-plus-5 arc through it.
The TRF schedule is legislated, and the facility closes. 12% to 5 April 2027, 15% to 5 April 2028, then nothing.

The constraint none of these regimes solve

Every one of them requires you to have genuinely left somewhere else. A Cypriot non-dom position is worth nothing against a former home jurisdiction that still considers you resident, and none of these regimes protects against that claim. The regime is the second question. The exit is the first.