The United Kingdom's Non-Domiciled Resident regime — known simply as Non-Dom — was one of the longest-running and most significant tax advantages available to internationally mobile individuals choosing to live in the UK. It allowed UK residents who were not UK-domiciled to pay UK tax only on income and gains remitted to the UK, leaving foreign income and gains outside the UK entirely exempt unless brought into the country. This regime attracted a significant number of international entrepreneurs, investors, and executives to London in particular.

From 6 April 2025, the Non-Dom regime was abolished and replaced by a new system — the Foreign Income and Gains (FIG) regime. For anyone whose financial planning relied on Non-Dom status, the transition requires immediate attention.

The new Foreign Income and Gains regime

The FIG regime is available to individuals who have not been UK tax resident in the preceding 10 consecutive tax years. For these individuals, the first four consecutive UK tax years of residence are treated favourably: foreign income and gains are entirely exempt from UK tax, regardless of whether they are remitted to the UK or not. No remittance restriction applies — money can be freely moved to and from the UK during this four-year window. After four years of UK residence, the FIG exemption ends and the individual becomes fully taxable on worldwide income and gains under the standard UK rules.

The critical difference from the old Non-Dom regime: the FIG exemption is time-limited to four years, and it only applies to genuinely new UK residents who have been non-resident for a decade. Long-term UK residents who had been using Non-Dom status for many years — potentially indefinitely — lose access to any form of foreign income exemption from April 2025.

The Temporary Repatriation Facility

For individuals who held foreign income and gains under the old remittance basis that had not yet been brought to the UK, HMRC introduced the Temporary Repatriation Facility (TRF). This allows pre-April 2025 unremitted foreign income and gains to be designated and brought to the UK at a reduced tax rate over a three-year window: 12% in the 2025-26 and 2026-27 tax years, and 15% in 2027-28. After 2028, undesignated pre-April 2025 foreign income and gains remitted to the UK will be taxed at standard rates. For anyone with significant accumulated foreign income under the old regime, the TRF window represents a genuinely useful exit mechanism.

Overseas Workday Relief

A separate relief — Overseas Workday Relief (OWR) — applies to the first three UK tax years for new UK residents with employment income partly earned from duties performed outside the UK. The proportion of employment income attributable to overseas work duties is not subject to UK tax during this three-year window. OWR is of particular relevance to executives who spend significant time working in multiple countries.

What internationally structured businesses should consider

The abolition of Non-Dom creates several planning considerations for those affected. For individuals whose primary reason for UK residence was tax efficiency under Non-Dom, alternative jurisdictions are worth reviewing — Malta's permanent residency programme and its non-dom-equivalent regime, Portugal's now-reformed NHR scheme, Cyprus's non-dom provisions, and Monaco and Dubai for those with more flexibility. For those who remain UK resident, the first four years of FIG are still genuinely favourable for new arrivals, and the TRF window provides a defined path for dealing with historic offshore accumulations. N3XTLV's advisory team can review your specific situation and help identify which structures remain viable under the new rules.