Non dom winners and losers under FIG rules

9 Sep 2025

Stephen Kenny, head of private client at PKF Littlejohn, explains the foreign income and gains (FIG) regime, the potential for use by Brits living abroad and looking to return, and for non doms facing high inheritance tax charges on worldwide income

There are rare moments in the world of tax when everything changes, the established order is upended, and the rulebook is totally rewritten. The abolition of the concepts of domicile and remittance basis for non-doms and the introduction of the foreign income and gains (FIG) regime is one such occasion.

The new FIG regime came into effect on 5 April 2025. Under FIG, individuals who have been non-residents for 10 years are able to exempt foreign income and gains from UK tax. There are also significant changes to inheritance tax (IHT), with a move to a residence-based test for inheritance tax rather than domicile.

Your free features:

Breaking news and expert analysis
Customisable daily newsletters
Six free CPD learning modules each year
Personalised CPD tracker
Top 75 Firms league tables
Regulatory changes
Hardman’s Tax Data

Tax | Tax traps for Harry and Meghan on return to UK

Tax | Brits quitting the Gulf over war have 60-day tax window

Tax | Personal tax changes from 6 April 2026

Tax | 10-year tax clock for expats planning UK return from Middle East conflict

Tax | Q&A: tax liability under foreign income & gains regime

Navigate

Tax Services

Your free features:

Sign up to Business & Accountancy Daily