The U.K.’s New Foreign Income and Gains Regime: Navigating the Changes
The concept of domicile has formed an integral part of the UK’s tax system since the 18th century.
Determining the extent to which certain non-U.K.-domiciled individuals (Non-Doms) are subject to income tax, capital gains tax, and inheritance tax. However, this is changing. With the abolition of domicile and the remittance basis of taxation (the Non-Dom regime) and, in its place, the introduction of the Foreign Income and Gains (FIG) regime, with effect from 6 April 2025.
This new regime represents a fundamental shift in how the U.K. will tax certain individuals’ foreign income and gains, posing challenges for internationally mobile employees and for global mobility professionals who oversee expatriate assignments. As the FIG regime replaces the long-standing remittance basis for non-Doms, both individuals and organisations will need to reassess their tax strategies and policies so that they are not caught flat-footed by the changes.
