Non Dom Regime Scrapped

As was widely rumoured, the Chancellor ‘stole’ Labours pledge to abolish the tax benefits for non-UK domiciled individuals by announcing that he would scrap the current regime.

New Measures

From 6 April 2025 the current remittance basis of taxation for non-UK domiciled individuals will be abolished and replaced by the foreign income and gains regime ‘FIG’.  There will be transitional provisions for individuals utilising the current non-dom rules. The new FIG regime will apply to individuals who became UK tax resident after a period of 10 years of non-UK residence.  

Under the FIG regime individuals will not pay UK tax on any foreign income or gains in the first four years of UK tax residence. Individuals choosing to be taxed under the FIG regime will lose entitlement to personal allowances and the capital gains tax annual exempt amount in the same way as the current non-dom rules.

There are transitional provisions proposed for those currently using the non-dom rules:

  • Option to rebase assets held to 5 April 2019 values.
  • Individuals who are UK resident for less than four years on 6 April 2025 (following a period of 10 years of non-UK tax residence) will be able to use FIG regime for four years.
  • Individuals moving from the remittance basis to the arising basis on 6 April 2025 who are not eligible for the FIG regime will pay tax on 50% of their foreign income (not gains) in 2025/26.
  • Temporary two-year repatriation facility to bring previously accrued foreign income and gains into the UK at a 12% rate of tax.  

There will also be a consultation to move to a residence-based regime for inheritance tax from 6 April 2025.