New Residence Based Tax Regime

Question 1

What is the new UK tax system for “non-dom” individual’s based on

Answer 1

Residency

Question 2

Who is considered a new resident in the UK

Answer 2

Not UK tax resident in previous 10 years

Question 3

What regime applies to new UK residents?

Answer 3

Foreign Income and Gains (FIG) Regime

Question 4

How does the FIG regime work?

Answer 4

New residents can remit FIG for 4 years with no further charge

Question 5

What happens at the end of the 4 your FIG period?

Answer 5

Worldwide Income and Gains come into scope for UK taxation

Question 6

What facility to individual’s who previously claimed the remittance basis get?

Answer 6

Temporary Repatriation Facility

TRF

Question 7

How does the TRF work?

Answer 7

For FIG that arose before Apr 6 2025

25/26 & 26/27 - taxed at 12% if remitted and declared
27/28 - taxed at 15% if remitted and declared

Question 8

How does the TRF encourage remittance?

Answer 8

1) Reduced rates of taxation
2) Do not have to identify source of income - streamlining things

Question 9

What other incentive was introduced to encourage remittance of gains?

Answer 9

Rebasing of Assets

If you claimed the remittance basis between 17/18 - 24/25

Can rebase the value of foreign assets to their Apr 2017 value and only pay tax on the gain from that date

Question 10

To be able to rebase a foreign asset, what condition applies to the asset?

Answer 10

Must have been outside of the UK in the 24/25 tax year.

Question 11

How has IHT changed for non-domiciled individuals

Answer 11

No longer domicile based

If resident for 10 of last 20 tax years - worldwide estate is subject to IHT

Remain in scope for taxation for 3-10 years depending on length of residency