From 6 April 2025, the UK's non-domicile regime was replaced by a new residence-based system. The remittance basis: which allowed non-doms to pay UK tax only on UK income and gains, with overseas income and gains taxed only if remitted to the UK: no longer exists for new arrivals or for those who have been UK resident for more than four years.
The replacement is the Foreign Income and Gains (FIG) regime. New UK residents can elect to pay no UK tax on foreign income and gains for their first four years of UK residence. After four years, all worldwide income and gains are subject to UK tax, regardless of where they arise or whether they are remitted.
Who is affected
The change affects three groups of people in different ways.
New arrivals (from 6 April 2025 onwards): Four years of FIG relief, then full worldwide taxation. This is more generous than the old regime for the first four years, and significantly less generous thereafter.
Existing non-doms who have been UK resident for fewer than four years: They can use the FIG regime for the remainder of their four-year window, then move to full worldwide taxation.
Existing non-doms who have been UK resident for more than four years: The remittance basis is no longer available. All worldwide income and gains are now taxable in the UK. A transitional relief allows 50% of foreign income arising in 2025-26 to be exempt, but this is a one-year measure.
The overseas workday relief changes
Overseas workday relief (which allowed non-doms working partly outside the UK to exclude the overseas portion of their employment income from UK tax) has been reformed. It is now available for the first three years of UK residence, subject to the income being paid into an overseas account and not remitted to the UK during the relief period.
What this means for founders with overseas structures
If you have a corporate structure with overseas elements, an offshore holding company, overseas investment accounts, or a non-UK subsidiary: the income and gains arising in those structures are now subject to UK tax from year five of UK residence onwards. The question is not whether the income is remitted. It is whether it arises.
The Controlled Foreign Company rules, the Transfer of Assets Abroad legislation, and the new FIG regime interact in ways that require careful analysis for any founder with overseas corporate structures. The Capital Audit identifies whether your current structure has overseas elements that need to be reviewed in light of the April 2025 changes.
The Architecture That Survives the Rule Change
The non-dom rule changes are a Stability-layer event for founders who were relying on the remittance basis to protect overseas income. The remittance basis is gone. The four-year FIG regime is the replacement. Neither of these is an architecture. They are reliefs that Parliament can change again.
The Growth layer (a holding structure that separates UK and overseas income at the corporate level) is less vulnerable to personal tax rule changes because the income is not personal income until the founder chooses to extract it.
The Expansion layer is the constitutional architecture that governs how overseas capital is structured, protected, and eventually repatriated, so that the founder's position does not depend on a personal tax relief that has already been abolished once.