We recently spoke with an overseas business owner who had been told by three different people that he would owe significant UK tax on his overseas income the moment he arrived in the UK.
He wouldn't have. But nobody had taken the time to explain why — or what he needed to do before he got on the plane.
That conversation is more common than it should be. The rules around UK tax for internationally mobile individuals changed fundamentally on 6 April 2025, and a lot of the information circulating — even among advisers — is either out of date, overly technical or focused on the wrong question entirely.
This article is written for people in that situation. Not tax professionals. People who are planning a move to the UK, have income or assets overseas, and want to understand clearly what the current rules mean for them — and what they need to do about it.
This article is particularly relevant if you:
Until April 2025, the framework that governed how internationally mobile individuals were taxed in the UK was built around domicile — a concept with roots going back to the Napoleonic era. Non-domiciled individuals could elect to be taxed on the remittance basis, meaning overseas income was only taxable in the UK if it was brought here. Keeping funds offshore was the planning tool.
That regime has gone.
From 6 April 2025, domicile is no longer the determining factor for income tax and capital gains tax. All UK residents are now taxed on worldwide income and gains as they arise — regardless of whether those amounts ever reach the UK.
The problem is that a significant amount of advice, content and planning being offered to internationally mobile individuals is still framed around the old rules. If someone is advising you based on the remittance basis without acknowledging that it no longer exists in its previous form, that is worth questioning.
The Foreign Income and Gains regime — the FIG regime — was introduced alongside the removal of the remittance basis. It provides qualifying individuals with a complete exemption from UK tax on foreign income and gains during their first four tax years of UK residency.
Crucially, unlike the old remittance basis, the FIG regime does not require you to keep funds offshore to benefit from the exemption. Foreign income and gains relieved under FIG can be freely brought into the UK during the four-year window without triggering any UK tax charge. That is a significant practical difference for anyone who needs to fund their life in the UK from overseas income.
After four years, the exemption ends. From year five, the individual is fully taxable on worldwide income and gains — the same as any other UK resident. That transition is important to plan for, and it should not be left until year four to think about.
To access the FIG regime, you must:
The regime is also available to former UK residents who have been outside the UK for ten or more years — a group who would not have been eligible for the old remittance basis at all.
One trade-off worth understanding: claiming FIG relief means forfeiting your UK personal allowance (currently £12,570) and annual CGT exemption (currently £3,000) for that year. For individuals with modest levels of overseas income, those allowances may be worth more than the FIG exemption. It is not automatically the right choice in every year — the numbers need to be run.
For individuals who arrived before 6 April 2025 and were using the remittance basis, foreign income and gains that arose before that date and remained unremitted continue to be governed by the old rules. Those amounts stay outside UK tax unless brought to the UK.
A Temporary Repatriation Facility exists to allow those historical amounts to be brought to the UK at a reduced flat rate — 12% in 2025/26 and 2026/27, rising to 15% in 2027/28. That window closes after 2027/28. For anyone sitting on significant unremitted pre-April 2025 income, the decision of whether to use this facility needs to be made before the deadline passes.
The introduction of the FIG regime does not reduce the importance of planning before you arrive. It makes it more important.
The ten-year non-residency condition has to be satisfied before you set foot in the UK as a resident. The four-year clock starts from your first year of UK residency — so arriving without having thought about this means potentially losing part of the window before you even know it exists. And for individuals with income from multiple jurisdictions, overseas company structures or significant accumulated overseas wealth, the interaction between FIG, UK-sourced income and your specific circumstances needs to be worked through carefully before day one.
We worked with an overseas national whose business was expanding into the UK for an expected two to three year period. He had substantial income from overseas business interests across multiple jurisdictions and no anticipated UK-sourced earnings during his stay. We were engaged well before his arrival date — which gave us time to review his full income picture, understand his objectives and structure his UK residency properly.
By planning his position in advance — including structuring capital transfers before UK residency commenced — we ensured he arrived with no unexpected UK tax exposure on his overseas income, the funds he needed accessible in the UK without triggering a tax charge, and the flexibility to remain longer if his business required it.
Read our International Relocation Tax Planning Case Study to see how pre-arrival planning helped an overseas business owner prepare for UK residency. That case was completed under the remittance basis before April 2025. The same principle — that early engagement creates significantly better outcomes — applies equally under the FIG regime.
Do you qualify for the FIG regime? Ten consecutive years of non-UK residency before arrival is the condition. If you do not meet it, you will be taxable on worldwide income from day one.
What does your overseas income look like? The FIG regime exempts foreign income and gains during the four-year window, but the interaction with UK-sourced income, employment earnings and international structures requires careful analysis for each year.
Is forfeiting your personal allowance worth it? Claiming FIG relief costs you the personal allowance and annual CGT exemption for that year. At lower income levels the trade-off may not be beneficial — it needs to be calculated, not assumed.
Do you have unremitted income from before April 2025? If you were a remittance basis user, the Temporary Repatriation Facility may be worth using before the reduced rate window closes after 2027/28.
When does your four-year window close? If you have already been UK resident for one or two years, the remaining window is shorter than you may think. Planning for the transition at year five should start well before then.
The business owner we mentioned at the start of this article arrived in the UK with complete clarity on his tax position — no surprises, no unexpected liabilities, no scrambling to restructure after the fact. That outcome came entirely from having the right conversation before he arrived, not after.
The FIG regime offers a genuinely valuable window for qualifying individuals. Whether that window is fully used, partially used or inadvertently lost often comes down to one thing: when the planning conversation happens.
Our accountants in Weybridge and Twickenham work with internationally mobile individuals, overseas business owners and private clients relocating to the UK. If you want to understand how the FIG regime applies to your specific situation, find out more about our UK Tax Advice for International Individuals here or visit our accountancy page.