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Non-Domiciled Residents UK Tax Guide 2026/27 | FIG Regime, TRF, IHT | UK Tax Hero
Cross-Border · Non-Doms · 2022/23–2026/27

Non-domiciled residents —
HMRC's new rules.

A comprehensive summary of HMRC's published guidance on the Finance Act 2025 reforms: the FIG regime, Temporary Repatriation Facility, IHT 10-out-of-20 rule, CGT rebasing, mixed funds and offshore trust structures — with five years of rates and direct GOV.UK links.

Read the guide → Speak to a specialist
✓ HMRC sources only ✓ GOV.UK links throughout ✓ 2022/23–2026/27 ✓ Not financial advice

Non-Dom Tax 2026/27

🏛️ HMRC
FIG relief period4 years (100%)
TRF rate 2025/26–2026/2712% flat
TRF rate 2027/2815% flat
IHT threshold (worldwide)10/20 years
Source: HMRC / GOV.UKUpdated May 2026
Non-dom specialists
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HMRC published key figures

Key non-dom figures.

All figures sourced from HMRC's published guidance. Verify on GOV.UK.

4 yrs
FIG regime relief — 100% on foreign income & gains · GOV.UK
12%
TRF flat rate 2025/26 & 2026/27 · RDRM73000
15%
TRF rate 2027/28 — final year · TRF closes 5 April 2028
10/20
IHT long-term resident test — worldwide assets in scope · GOV.UK
HMRC guidance summary

The biggest shift in 200 years of UK tax.

According to HMRC's published guidance, the Finance Act 2025 abolished the concept of domicile for UK Income Tax and CGT purposes from 6 April 2025 — replacing a system that had been in place for over 200 years with a straightforward residence-based framework. This page summarises what HMRC's rules now say. It is not tax advice — always verify on GOV.UK and speak with a qualified adviser.

Contents — quick navigation
📌 HMRC's position — key change

From 6 April 2025, domicile is no longer relevant for UK Income Tax or CGT. According to HMRC's GOV.UK guidance, all UK residents are now taxed on worldwide income and gains on the arising basis — unless they qualify for the 4-year FIG regime as a new arrival.

HMRC guidance: FIG regime

The 4-year FIG regime — HMRC's rules.

According to HMRC's published guidance on non-domiciled residents, the Foreign Income and Gains (FIG) regime provides 100% relief on foreign income and gains for qualifying new residents. HMRC confirmed this is an objective, residence-based test — there is no subjective 'intent to remain' assessment, unlike the old domicile rules.

Qualifying conditions per HMRC's published guidance 📄 GOV.UK

  • You must be UK resident under the Statutory Residence Test for the tax year in question.
  • You must have been non-UK resident for at least 10 consecutive tax years immediately before your first qualifying year of UK residence. The 10-year period is tested under the SRT for years from 2013/14 onwards.
  • You must claim the relief each year on your Self Assessment return — it is not automatic. The claim is made on the SA109 alongside the SA100.
  • You are not a member of the House of Commons or House of Lords.

What FIG covers — and what it doesn't 📄 GOV.UK

✅ What HMRC says FIG covers

  • Foreign investment income — dividends, interest, overseas rental income
  • Foreign capital gains on non-UK assets
  • Foreign employment income (subject to OWR rules — see HMRC's OWR guidance)
  • Funds remitted to the UK during the 4-year window — no further UK tax on FIG brought to UK in years 1–4

❌ What HMRC says FIG does NOT cover

  • UK-source income of any kind — always taxable on the arising basis. GOV.UK
  • CGT on UK land and property — always taxable for UK residents regardless of FIG status
  • Years 5+ of UK residence — FIG relief ceases; worldwide arising basis applies automatically
  • Years of non-UK residence — cannot claim FIG if not UK resident that year
  • Members of the House of Commons or Lords — expressly excluded

The 4-year clock — how it runs per HMRC's rules

HMRC's guidance confirms the four-year period runs from your first year of UK residence after the qualifying 10-year absence — not from 6 April 2025. Individuals who became UK resident before April 2025 may still have qualifying FIG years remaining.

First year of UK residenceFIG years available after 6 April 2025FIG expires
2022/232025/26 only (year 4)After 5 April 2026
2023/242025/26 & 2026/27 (years 3–4)After 5 April 2027
2024/252025/26, 2026/27, 2027/28 (years 2–4)After 5 April 2028
2025/262025/26 – 2028/29 (years 1–4)After 5 April 2029
2026/27 onwardsFull 4 years from arrival4 years after first residence year

Source: GOV.UK — Non-domiciled residents. Individuals who left the UK temporarily during their four-year period may be able to claim FIG for remaining qualifying years on return — see HMRC's guidance.

Illustrative example — not advice

FIG regime: year-by-year (illustrative, based on HMRC's published rules)

First UK residence year after 12-year absence2025/26 (Year 1)
Foreign investment income all 4 yearsFIG claimed — nil UK tax
UK salary throughoutTaxable at standard rates every year
Year 5 (2029/30)All worldwide income taxable on arising basis
Claim on SA100 + SA109 each year — verify eligibilityGOV.UK →

Illustrative only. Eligibility depends on your specific residence history under the SRT. Not tax advice.

📄
GOV.UK: Non-domiciled residents & FIGHMRC's official guidance on the FIG regime
📘
HMRC RDRM ManualFull residence, domicile & FIG internal manual
📋
HMRC Technical Note — non-dom reformsHMRC's full technical note on Finance Act 2025 changes
HMRC guidance: TRF

Temporary Repatriation Facility — rates, deadlines & mechanics.

The TRF is documented in HMRC's internal manual RDRM73000 and legislated under Finance Act 2025, Schedule 2. It is available to former remittance-basis users who have pre-April 2025 untaxed foreign income and gains (FIG) offshore. The TRF also applies to FIG held in assets — not only cash.

HMRC's published TRF rate schedule 📄 RDRM73000

PhaseTax yearsTRF charge rateStandard marginal rate (if not using TRF)Status
Phase 12025/26 & 2026/2712%Up to 45%Open now
Phase 22027/2815%Up to 45%Opens April 2027
Phase 3From 6 April 2028ClosedUp to 45%TRF permanently closed

Designate Now, Remit Later — HMRC's confirmed mechanics

A critical feature of the TRF — confirmed in HMRC's RDRM73000 — is that designation on a Self Assessment return and payment of the TRF charge is all that is required to secure the reduced rate. The funds do not need to be physically moved to the UK at the time of designation. Once designated and the charge paid, those funds become 'TRF capital' (defined in RDRM75100) and may be remitted to the UK at any future date — including after the TRF window closes — with no further UK tax charge.

📅 Critical deadline: 31 January 2028 — per HMRC's Self Assessment rules

To lock in the 12% rate for the 2025/26 tax year, HMRC's rules require the designation to appear on a Self Assessment return that is filed or amended by 31 January 2028 (the amendment deadline for 2025/26 returns). Designations in the 2026/27 return (filed by 31 Jan 2027, or amended by 31 Jan 2028) also attract 12%. The 15% rate applies to the 2027/28 return only. After 5 April 2028, the TRF is permanently closed.

Who can use the TRF — HMRC's eligibility rules

  • Former remittance-basis users who are currently UK resident and have pre-April 2025 FIG that has not yet been remitted to the UK.
  • The FIG must have arisen to the individual personally in a year when they were on the remittance basis. RDRM73000
  • The TRF is also available to UK resident settlors or beneficiaries of offshore trust structures where benefits are matched to pre-April 2025 FIG.
  • FIG that has already been remitted and taxed cannot be redesignated under the TRF.
  • FIG arising from criminal activity is excluded.
Illustrative example — based on HMRC's published rates

TRF designation: illustrative figures

Pre-April 2025 unremitted FIG (hypothetical)£500,000
Designated in 2025/26 or 2026/27 return£500,000
TRF charge (12% per HMRC RDRM73000)£60,000 — payable on designation
Equivalent charge at additional rate (45%)£225,000 (illustrative)
Funds become TRF capital — remit anytimeNo further UK tax on remittance
Verify eligibility and mechanics with a specialistFind a specialist →

This illustrates HMRC's published rates applied to hypothetical figures. Actual liability depends on individual circumstances. Not tax advice.

📘
HMRC RDRM73000 — TRF overviewScope, mechanics and designation rules
💳
TRF & Remittance GuideFull guide with HMRC source references
📄
GOV.UK: Technical amendments to residence-based regimeHMRC's 2026 technical amendments policy paper
HMRC guidance: RDRM75000

Mixed funds & TRF capital accounts — HMRC's RDRM75000.

According to HMRC's manual RDRM75100, a 'mixed fund' is an overseas account or asset containing more than one type of income or capital — for example, pre-arrival clean capital combined with untaxed foreign income or gains. The TRF introduces new rules to help former remittance-basis users manage and designate the taxable portions of such accounts.

TRF capital takes priority in mixed funds — per HMRC RDRM75200 📄 RDRM75200

Finance Act 2025 introduced a new Step A1 to section 809Q ITA 2007. According to HMRC's RDRM75200, TRF capital is treated as remitted in priority to all other types of income and capital in the mixed fund. This means:

  • Once designated at 12%, TRF capital is the first money treated as leaving a mixed account when remittances are made.
  • The remaining balance (clean capital, other income) is not treated as remitted until all TRF capital has been used.
  • HMRC's manual also confirms an annualised basis applies during the TRF period — all remittances in a tax year are treated as a single remittance at year end, simplifying the composition calculation. See RDRM75500.

TRF capital account — HMRC RDRM75310 📄 RDRM75310

According to HMRC's RDRM75310, individuals who have made a partial designation within a mixed fund may transfer their TRF capital into a special nominated overseas bank account — the TRF capital account. This account:

  • Can only hold TRF capital (and interest accruing on it).
  • Allows the individual to track and control when TRF capital is remitted to the UK.
  • Prevents TRF capital from being inadvertently spent offshore (which would reduce the amount available to bring to the UK tax-free).
  • Must be nominated by the individual — HMRC's rules for valid nomination are in RDRM75320.

⚠️ TRF capital account breach rules — HMRC RDRM75340

According to HMRC's RDRM75340, paying anything other than TRF capital (and interest on it) into a TRF capital account constitutes a breach. Breaches on more than two days in a tax year cannot be remedied and may cause the account to cease to be a TRF capital account, with adverse tax consequences. HMRC's guidance recommends careful management of nominated accounts.

📘
HMRC RDRM75100 — TRF & mixed fundsTRF capital definition and mixed fund rules
📘
HMRC RDRM75200 — Remittances from mixed fundsStep A1 priority ordering rules
📘
HMRC RDRM75310 — TRF capital accountTransfers to and from TRF capital accounts
📘
HMRC RDRM75500 — Annualised basisSimplified composition rules during TRF period
HMRC guidance: IHT

Inheritance Tax — HMRC's 10-out-of-20 rule.

According to HMRC's published IHT guidance on GOV.UK and the Finance Act 2025 technical amendments, from 6 April 2025 the IHT regime for non-UK assets is based on long-term UK residence rather than domicile. The 40% IHT rate on worldwide assets applies once the long-term residence threshold is met.

The long-term residence test — HMRC's published rule 📄 GOV.UK

According to HMRC's guidance, an individual becomes a 'long-term UK resident' — and thereby subject to IHT on worldwide assets — when they have been UK resident in at least 10 of the preceding 20 tax years immediately before the relevant date (death, gift or trust charge). This is assessed each time a chargeable event occurs.

The 10-year tail — HMRC's published rule

According to HMRC's published guidance, once the 10-out-of-20 threshold is met, a tail period of up to 10 years applies after leaving the UK. Worldwide assets remain within the scope of UK IHT for a period after departure that depends on how long the individual was UK resident:

Years of UK residence (when leaving)IHT tail period after departureHMRC source
10 years3 yearsGOV.UK
11 years4 yearsGOV.UK
12 years5 yearsGOV.UK
13 years6 yearsGOV.UK
14 years7 yearsGOV.UK
15–19 years8 yearsGOV.UK
20 years10 yearsGOV.UK

📋 IHT and split years from April 2025

According to HMRC's published guidance, from 6 April 2025 a split year is treated as a full year of UK tax residence for the purposes of counting towards the 10-year IHT threshold. A year in which you leave or arrive part-way through still counts as a full IHT year.

⚠️ Transitional rules — individuals who left the UK before April 2025

According to HMRC's published technical note, individuals who were non-UK resident in 2025/26 and were not UK domiciled as of 30 October 2024 continue to be governed by the old domicile-based IHT rules for their existing non-resident position — they do not immediately fall under the new 10/20 rule. However, if they return to the UK in future, the new residence-based rules will apply going forward. See HMRC's technical amendments guidance.

📄
GOV.UK: Inheritance TaxHMRC's main IHT guidance page
📘
HMRC: Inheritance Tax ManualHMRC's detailed IHT internal manual
📄
GOV.UK: Technical amendments 2026HMRC's policy paper on residence-based IHT changes
HMRC guidance: CGT rebasing

CGT rebasing to 5 April 2017 — HMRC's transitional relief.

According to HMRC's published guidance on the Finance Act 2025 transitional provisions, eligible individuals can rebase the cost of certain foreign assets to their market value on 5 April 2017 for UK CGT purposes. This removes gains accrued before that date from the UK CGT calculation on a future disposal.

Eligibility conditions — per HMRC's guidance

  • The individual must have been a non-UK domiciled individual immediately before 6 April 2025 (i.e. a former non-dom under the old rules).
  • The individual must have claimed the remittance basis in at least one tax year before 6 April 2025.
  • The asset must be a foreign chargeable asset held personally (not in a trust) — UK assets are not eligible.
  • The asset must have been held by the individual on both 5 April 2017 and at the date of disposal.

⚠️ Rebasing is not automatic — HMRC's rules

According to HMRC's published guidance, rebasing to the April 2017 value is an election — it must be claimed. If rebasing to the 2017 value would increase the gain (i.e. the asset fell in value between 2017 and disposal), the individual may be better off using the original acquisition cost. HMRC's guidance confirms that strict conditions apply and the rules are technically complex — each case requires careful analysis. See HMRC's RDRM manual.

HMRC guidance: offshore trusts

Offshore trust structures — HMRC's position from April 2025.

According to HMRC's published guidance, the Finance Act 2025 made significant changes to how offshore trust structures are taxed for UK-resident individuals. The historic 'protected settlements' regime — which shielded offshore trust income and gains from tax for non-dom settlors — was abolished from 6 April 2025.

Key changes to offshore trusts per HMRC's guidance

  • UK-resident settlors who have been UK resident for more than four years are now taxed on trust income and gains on the arising basis — the same as for direct holdings. HMRC RDRM Manual
  • Qualifying new residents in their first four FIG years may continue to benefit from the regime for trusts — foreign trust income and gains can be excluded during the FIG period, subject to the FIG eligibility conditions.
  • IHT and offshore trusts: According to HMRC's guidance, when a settlor is a long-term UK resident, assets settled in trust — even when settled while non-UK resident — may become subject to IHT charges. Exit charges may apply when trust assets cease to be relevant property as a result of a change in the settlor's residence status.
  • A £5 million cap on relevant property IHT charges over each 10-year cycle applies to trusts that held excluded property as at 30 October 2024, per the Autumn Budget 2025 announcement. See HMRC's IHT manual.
Complex area — specialist advice important

Offshore trust structures require detailed specialist review

HMRC's published guidance on offshore trusts under the new residence-based regime is extensive and fact-specific. Transitional rules, the TRF window and IHT exit charges all interact in complex ways. Our free matching service can connect you with verified UK specialists in non-dom and offshore trust taxation.

HMRC enquiries & disclosures

HMRC investigations — what the guidance says.

According to HMRC's guidance on automatic exchange of information, HMRC receives financial account data from over 100 countries under the Common Reporting Standard. This covers bank accounts, investments, insurance products and offshore trust distributions. HMRC's published guidance confirms that domicile status remains relevant for enquiries into years before 2025/26, when the remittance basis was still available — HMRC can and does challenge historic remittance-basis claims.

⚠️ HMRC's required disclosure route for offshore matters

According to HMRC's WDF guidance, where undisclosed offshore income or gains are involved, the Worldwide Disclosure Facility is the required route for making a disclosure — amending a Self Assessment return alone is not sufficient. HMRC's published penalty guidance confirms offshore penalties can reach 200% of tax owed, but voluntary unprompted disclosure substantially reduces this. See GOV.UK: offshore penalty guidance.

📬
HMRC Nudge Letter GuideWhat nudge letters mean and HMRC's disclosure process
📄
GOV.UK: Worldwide Disclosure FacilityHMRC's required route for offshore disclosures
📄
GOV.UK: Digital Disclosure ServiceHMRC's online portal for voluntary corrections
HMRC published rates 2022/23–2026/27

Five years of official figures.

Regime history — remittance basis to FIG 📄 GOV.UK

Tax YearRegimeForeign income treatmentTRF rateHMRC source
2022/23Remittance basisTaxable only if remitted to UKN/AGOV.UK
2023/24Remittance basisTaxable only if remitted to UKN/AGOV.UK
2024/25Remittance basis (final year)Taxable only if remitted to UKN/AGOV.UK
2025/26FIG regime / arising basisFIG claimants: 0% on foreign income; others: worldwide arising12% on pre-Apr 2025 FIGRDRM73000
2026/27FIG regime / arising basisFIG claimants (years 1–4): 0%; others: worldwide arising12% on pre-Apr 2025 FIGRDRM73000

CGT rates — all assets 📄 GOV.UK

Tax YearAnnual Exempt AmountBasic rateHigher/add. rateNotes
2022/23£12,30010%20%
2023/24£6,00010%20%
2024/25 (to 29 Oct 2024)£3,00010%20%Pre-Budget
2024/25 (from 30 Oct 2024)£3,00018%24%Post-Autumn Budget 2024
2025/26£3,00018%24%Confirmed
2026/27£3,00018%24%Confirmed

Source: GOV.UK — Capital Gains Tax rates

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Estimate using HMRC's published rates.

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Need personal advice on the FIG regime or TRF?

This page summarises HMRC's published guidance — it is not personal tax advice. The FIG regime, TRF, IHT tail and offshore trust changes are highly fact-specific. Our free matching service connects you with verified UK specialists within 24 hours. No charge, no obligation.

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Common questions

Non-Dom & FIG FAQs

Answers based on HMRC's published guidance with GOV.UK source links. Not tax advice — verify your position with a qualified professional.

What replaced the remittance basis from 6 April 2025?
According to HMRC's published guidance, the Finance Act 2025 abolished the remittance basis from 6 April 2025 and replaced it with the Foreign Income and Gains (FIG) regime. Qualifying new residents who have been non-UK resident for at least 10 consecutive years may claim 100% relief on foreign income and gains for their first four tax years of UK residence. From year five, worldwide income and gains are taxed on the arising basis at standard rates. Domicile is no longer relevant for Income Tax or CGT.
Who qualifies for the FIG regime?
Per HMRC's published guidance, qualifying conditions are: (1) UK resident under the SRT in the relevant year; (2) non-UK resident for at least 10 consecutive years before the first qualifying year; (3) the individual is not a member of the House of Commons or Lords; (4) the relief is claimed annually on the Self Assessment return (SA100 + SA109) — it is not automatic.
Can I claim FIG if I became UK resident before April 2025?
Yes — per HMRC's guidance, the FIG clock runs from your first year of UK residence after the 10-year qualifying absence, not from April 2025. If you became UK resident in 2023/24 having been non-resident for 10+ years, you can claim FIG for 2025/26 and 2026/27 (years 3 and 4). If you became UK resident in 2022/23, only 2025/26 (year 4) may remain. Verify your specific years against HMRC's FIG guidance.
What income is NOT covered by the FIG regime?
According to HMRC's guidance, the FIG regime does NOT cover: UK-source income (always taxable on arising basis); CGT on UK land and property; income or gains in years 5+ of UK residence; and income in any year you are not UK resident. The FIG regime covers foreign income and gains only.
Is domicile still relevant for UK tax after April 2025?
For Income Tax and CGT purposes, domicile is no longer relevant from 6 April 2025 — residence determines worldwide tax exposure. However, per HMRC's guidance, domicile remains relevant for: (1) IHT on trusts settled before April 2025, where domicile at settlement affects excluded property rules; (2) HMRC enquiries into years before 2025/26 when the remittance basis was claimed; and (3) certain succession and private international law matters. See HMRC RDRM Manual.
Do I lose my Personal Allowance if I claim FIG?
Claiming the FIG regime itself does not cause loss of the Personal Allowance. However, making an Overseas Workday Relief (OWR) election within the FIG framework does cause the loss of the Personal Allowance and CGT annual exempt amount for that year, per HMRC's OWR guidance. The FIG claim itself (without an OWR election) preserves the Personal Allowance.
What is the TRF and who can use it?
According to HMRC's RDRM73000, the TRF is available to former remittance-basis users who are UK resident and have pre-April 2025 foreign income and gains (FIG) that have not yet been remitted to the UK. Designation is made on a Self Assessment return and a flat charge is paid (12% in 2025/26–2026/27, 15% in 2027/28). The TRF also applies to FIG held in assets and to offshore trust structures where benefits are matched to pre-April 2025 FIG.
Do I need to move the money to the UK when I designate under the TRF?
No — per HMRC's RDRM73000, the TRF operates by designation on a Self Assessment return. Once designated and the charge paid, funds become TRF capital and may be remitted to the UK at any future date — including after the TRF window closes on 5 April 2028 — with no further UK tax. This is sometimes called "Designate Now, Remit Later."
What is the deadline to secure the 12% TRF rate for 2025/26?
Per HMRC's Self Assessment amendment rules, the deadline to lock in the 12% rate for the 2025/26 tax year is 31 January 2028 — the amendment deadline for 2025/26 returns. The designation must appear on a return filed or amended by that date. Designations in the 2026/27 return (filed by 31 Jan 2027 or amended by 31 Jan 2028) also qualify for 12%. The TRF closes permanently after 5 April 2028. See HMRC RDRM73000.
How does the TRF work for mixed offshore accounts?
According to HMRC's RDRM75100 and RDRM75200, Finance Act 2025 introduced Step A1 under section 809Q ITA 2007: TRF capital is treated as remitted in priority to all other income and capital in a mixed fund. HMRC also provides for a TRF capital account (RDRM75310) where designated funds can be held separately to prevent them being spent offshore unintentionally.
Can the TRF be used for FIG held in assets (not cash)?
Yes — per HMRC's guidance, the TRF applies to unremitted FIG that has been invested in assets — not only funds held as cash in bank accounts. The designation covers the income and gains represented by the asset, not the asset itself. This is particularly relevant for former non-doms whose pre-April 2025 FIG has been reinvested offshore.
What happens if I do not use the TRF before it closes?
According to HMRC's published guidance, after 5 April 2028 the TRF is permanently closed. Pre-April 2025 FIG that has not been designated under the TRF and is subsequently remitted to the UK will be taxable at the individual's full marginal rate — up to 45% Income Tax or 24% CGT. There is no further concessionary rate available after the TRF window closes. See HMRC RDRM73000.
What is HMRC's 10-out-of-20 IHT rule?
According to HMRC's published guidance, from 6 April 2025 UK IHT on worldwide assets applies when an individual has been UK resident in at least 10 of the preceding 20 tax years — the 'long-term resident' test. The 40% IHT rate on worldwide assets applies from that point. A tail period of 3–10 years (depending on total years of UK residence) means worldwide assets remain within IHT scope after leaving the UK. See GOV.UK: Inheritance Tax.
How long is the IHT tail after leaving the UK?
According to HMRC's published guidance, the tail period ranges from 3 years (for someone who has been UK resident for exactly 10 years) to 10 years (for someone resident for 20 years). The tail runs from the date of departure. During the tail period, worldwide assets remain subject to UK IHT even though the individual is non-resident. The tail is extinguished after 10 consecutive years of non-UK residence — at which point the 10/20 clock resets. See GOV.UK: IHT.
Do split years count as full years for the IHT 10/20 test?
Yes — according to HMRC's published guidance on the Finance Act 2025 reforms, a split year is treated as a full year of UK tax residence for the purposes of counting towards the 10-year IHT threshold. The year you arrive in or leave the UK mid-year therefore still counts as a full year in the 10/20 calculation.
I left the UK before April 2025 — does the new IHT rule apply to me?
According to HMRC's published technical note, if you were non-UK resident in 2025/26 and were not UK domiciled as of 30 October 2024, the old domicile-based IHT rules continue to apply to your existing non-resident position. The new 10/20 rule does not apply retrospectively to those already outside the UK. However, if you return to the UK in future, the new rules will apply going forward. See HMRC's technical amendments.
What happened to offshore trust protection from April 2025?
According to HMRC's published guidance, the 'protected settlements' regime was abolished from 6 April 2025. UK-resident settlors who have been UK resident for more than four years are now taxed on trust income and gains on the arising basis — the same as direct holdings. Qualifying new residents in their first four FIG years retain some protection. See HMRC RDRM Manual.
What is CGT rebasing to 5 April 2017?
According to HMRC's published guidance on Finance Act 2025 transitional provisions, former non-doms who held foreign assets personally and had claimed the remittance basis may elect to rebase those assets' acquisition cost to their market value on 5 April 2017. This removes pre-2017 gains from the UK CGT calculation on future disposal. The election is not automatic — it must be claimed, and strict conditions apply. UK assets are not eligible for rebasing.
What CGT rate applies to gains on foreign assets by former non-doms?
Per HMRC's published CGT rates, from 30 October 2024 CGT rates are 18% (basic rate) and 24% (higher/additional rate) on most assets including foreign property and investments. The annual exempt amount is £3,000 for 2025/26 and 2026/27. Where FIG relief (FIG regime) is claimed, foreign gains are exempt from CGT for qualifying years.
Can HMRC enquire into years when I claimed the remittance basis?
Yes — according to HMRC's published guidance, domicile status remains relevant for HMRC enquiries into years before 2025/26 when the remittance basis was still available. HMRC can challenge historic remittance-basis claims, including questions about whether the individual was genuinely non-UK domiciled in those years. HMRC's standard time limits are 4 years (innocent error), 6 years (careless) and 20 years (deliberate offshore non-disclosure). See HMRC Enquiry Manual.
What is the WDF and why must it be used for offshore disclosures?
According to HMRC's published WDF guidance, the Worldwide Disclosure Facility is HMRC's required route for disclosing undeclared offshore income and gains — amending a Self Assessment return alone is not sufficient. Voluntary unprompted disclosure via the WDF attracts significantly lower penalties (0–30% for innocent errors in Category 1 territories) compared to HMRC-prompted disclosure (minimum 15–30%) or no disclosure (up to 200%).
I received a nudge letter about offshore investments — what does HMRC's guidance say to do?
According to HMRC's WDF guidance, a nudge letter about offshore assets indicates HMRC has data (from CRS exchanges or other sources) suggesting a possible discrepancy. The required route for any offshore disclosure is the WDF, not a simple return amendment. HMRC's guidance confirms that responding before HMRC opens a formal enquiry constitutes an unprompted disclosure, attracting lower penalties. For complex non-dom cases involving multiple years and assets, specialist advice on the scope of any required disclosure is important.
Where can I find all HMRC's official guidance on non-dom and FIG?
Key HMRC sources: GOV.UK: Non-domiciled residents · HMRC RDRM Manual · RDRM73000 (TRF) · RDRM75100 (mixed funds) · GOV.UK IHT · HMRC technical note on non-dom reforms.
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Information only — not tax or financial advice. This page summarises HMRC's published guidance on non-domiciled resident UK tax. Nothing constitutes personal tax advice. Always verify on GOV.UK and consult a qualified professional before acting.