United Kingdom · Tax regime
4-year Foreign Income and Gains regime
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Last verified July 2026
Live since 6 April 2025, replacing the remittance basis. Finance Bill 2025-26 makes a series of technical corrective amendments, most with retrospective effect to 6 April 2025.
This is the single most consequential change in European private wealth taxation this decade: the UK moved from a system where a non-dom could shelter offshore wealth for 15 years to one where relief lasts exactly 4, and where the concept of domicile has been deleted from the tax code entirely. The 4 years are also cleaner than the old remittance basis — relief applies whether or not you bring the money onshore, so FIG-relieved income can be spent freely in the UK.
The facts
- Total landed cost
- No charge to enter — unlike the old remittance basis charge of GBP 30k–60k a year. The real cost is the surrendered personal allowance and CGT annual exempt amount, plus the compliance burden of quantifying and disclosing every pound of relieved foreign income and gains on a UK tax return
- Physical presence
- Governed by the Statutory Residence Test; the regime requires UK residence, so there is no minimum-days planning to be done — the planning is about the 10-year clean break beforehand
- Family
- each individual qualifies on their own residence history — there is no family unit and no derivative benefit for a spouse
- Permanent residency
- n/a — a tax regime, not an immigration route; you need separate leave to remain
- Citizenship
- n/a
- Dual citizenship
- Permitted
- Requirements
- UK tax resident under the Statutory Residence Testat least 10 consecutive tax years of non-UK residence immediately before the first qualifying yearwithin the first 4 tax years of UK residenceclaim made through Self Assessment, with the relieved income and gains quantified and disclosed
What can go wrong
- Four years is not a strategy, it is a countdown. Year 5 taxes worldwide income and gains at full UK rates with no transition, and there is no extension, no roll-over of unused years, and no second bite.
- The 10-year prior non-residence test is absolute. A single UK-resident tax year inside the previous decade — including a split year, or a year of accidental residence under the Statutory Residence Test — disqualifies you entirely.
- Claiming FIG costs you the income tax and CGT personal allowances, the Married Couple's Allowance and Marriage Allowance. For someone with modest foreign income the claim can be actively loss-making; it must be modelled year by year, not claimed reflexively.
- Relieved FIG still counts toward adjusted net income, which drags in the High Income Child Benefit Charge and tax-free childcare entitlements.
- You must quantify and disclose the relieved amounts on the return. The old remittance basis let you keep offshore affairs opaque; FIG requires you to hand HMRC a full schedule of the very income you are not paying tax on.
- If you break residence mid-window and become non-resident, those years are simply lost — the remaining years survive but the clock does not pause.