A non-dom transition review is an examination of your personal tax position following 6 April 2025, when the remittance basis was replaced by a regime based on residence. The purpose is to establish which transitional mechanisms remain available to you, how long each window stays open, and what has to be decided before your next return is filed.
Below: how the new regime works, who benefits from a review, what it covers, how long it takes, and where people most often go wrong when working through it alone. Every figure and deadline quoted is taken from current GOV.UK and HMRC publications.
What changed for non-doms on 6 April 2025
The substance of the change is the test, not the rates. Until 6 April 2025, the UK tax exposure of many private clients was determined by domicile — a legal connection to a country that could survive decades of living elsewhere. From that date domicile ceased to be the governing factor for income tax and capital gains tax and, subject to specific transitional rules, for inheritance tax as well. What matters now is a person’s history of tax residence.
Under the policy paper published by HM Treasury and HMRC, the remittance basis was replaced by 100% relief on foreign income and gains for new arrivals in their first four years of UK tax residence, provided they were not UK tax resident in any of the ten consecutive years before arrival. Everything else is taxed on the arising basis rather than when funds are brought into the country.
| Element | Before 6 April 2025 | From 6 April 2025 |
|---|---|---|
| Governing test | Domicile and deemed domicile | History of UK tax residence |
| Foreign income and gains | Remittance basis, by claim | Arising basis; relief only under the 4-year FIG regime |
| Charge for using the regime | Remittance basis charge | Does not apply |
| Pre-April 2025 unremitted amounts | Taxable when remitted to the UK | Still taxable when remitted; the TRF offers a reduced rate |
| Inheritance tax on foreign assets | By domicile and deemed domicile | By long-term UK residence status |
The practical consequence is straightforward: anyone who spent years arranging their affairs around the concept of domicile is now working under a different set of rules, and the old logic does not carry over. That is why a review of the position has become a task in its own right, rather than a line item in the annual preparation of a Self Assessment tax return.
The gap between reading about the reform and understanding your own position is unusually wide here. The new regime contains several transitional mechanisms, and eligibility for each depends on individual history: when residence began, how many years it has run, whether the remittance basis was ever claimed, and which assets are held personally rather than through a structure.
Non-dom transition review: what the service involves
A non-dom transition review is neither the preparation of a return nor a general briefing on how UK tax works. It is a reconstruction of the facts: which tax years you were resident for under the statutory residence test, which amounts arose before 6 April 2025 and remain outside the country, which transitional reliefs apply to you, and in what order it is most efficient to use them.
The output is not an opinion but a calculation: a set of scenarios with tax figures attached and the deadline for each decision. A review of this kind is needed because the transitional mechanisms do not simply add up. Claiming one can restrict access to another, and several of the windows are measured in calendar tax years rather than in how long it takes to gather documents.
It helps to separate two questions that are often confused. The first is how much tax is due for the current year. The second is what to do with everything accumulated before April 2025. The first is answered through ordinary compliance work. The second can only be answered by a review, because separate rules — and separate, time-limited opportunities — apply to those historic amounts.
Who needs a review of their tax position
A review is not for everyone — it belongs to tax planning for wealthy families rather than being a universal exercise. It earns its place where there is accumulated history: foreign income from earlier years, assets bought long ago, structures created under the previous rules. Someone who arrived recently and whose income all arises in the UK will find the review reduces to a residence check and takes very little time.
In practice, the exercise is most useful in the following situations:
- the remittance basis was claimed in earlier years and foreign income or gains remain unremitted;
- UK residence began fairly recently and it is unclear whether the four-year relief still applies;
- residence has run for more than ten years and the succession consequences need to be understood;
- the individual is the settlor or a beneficiary of an offshore trust created before April 2025;
- a foreign asset acquired many years ago is about to be sold;
- leaving the UK is under consideration and the length of the remaining tax connection matters;
- employment duties are performed outside the UK and relief for overseas workdays may be available.
In each case the answer turns on the detail of a personal history rather than on a general rule. That is particularly true for anyone who combines several of these features — for instance, a recent arrival who was also UK resident many years earlier, since that earlier period bears directly on eligibility for the new-arrival relief.
Advantages of arranging a transition review with Imperial & Legal
- Assessment by a tax adviser and a lawyer together
- Modelling of several scenarios with figures before filing
- Verification of deadlines under each transitional relief
- Preparation of the technical position for correspondence with HMRC
- Alignment with immigration status and settlement plans
- Coordination of the tax picture with wills and trusts
- Support with the Self Assessment return in the following year
To see what that work consists of, it helps to look at its components. A transition review is not a single conclusion but a sequence of checks, any one of which can change the overall picture.
What a non-dom transition review examines in your own position
- Residence check under the statutory residence test by tax year
- Assessment of FIG regime eligibility and the remaining years
- Inventory of unremitted foreign income and capital gains
- Calculation of the TRF benefit across the three tax years
- Analysis of the asset base for rebasing to 5 April 2017
- Review of long-term residence status for inheritance tax
- Examination of offshore trusts and the settlor consequences
The order is deliberate. Residence is checked first because everything else follows from it: eligibility for the new-arrival relief, and the point from which the clock starts running for inheritance tax. The key components are worth setting out in more detail.
The four-year FIG regime: conditions and limitations
The FIG regime (foreign income and gains) gives full relief on foreign income and capital gains for the first four tax years of UK residence. There is a single condition, and it is a strict one: the individual must not have been UK tax resident for at least ten consecutive tax years before arriving. According to GOV.UK guidance, neither nationality, nor domicile at any time, nor any past ability to claim the remittance basis affects eligibility.
Qualifying amounts include profits of a trade carried on wholly outside the UK, profits of an overseas property business, dividends from non-UK resident companies and interest such as that paid on a foreign bank account. One useful feature: relief can be claimed selectively, source by source, rather than across all foreign income at once.
The relief has a price. In any year a FIG claim is made, the individual loses the personal allowance for income tax and the annual exempt amount for capital gains tax, along with the married couple’s allowance, marriage allowance and blind person’s allowance. Foreign losses cannot be claimed in that year and cannot be carried forwards or backwards. In some scenarios that makes the relief the more expensive option, which is a matter for calculation rather than assumption.
| FIG regime parameter | Position |
|---|---|
| Effective from | 6 April 2025 |
| Length of relief | 4 consecutive tax years from the start of UK residence |
| Prior residence condition | At least 10 consecutive years of non-UK tax residence |
| What is relieved | Foreign income and gains, claimed by chosen source |
| What is lost | Personal allowance, CGT annual exempt amount, certain allowances |
| How it is claimed | Self Assessment return, residence and foreign pages |
| Claim deadline | The anniversary of 31 January following the end of the tax year |
A separate question arises for those who became resident before 6 April 2025. Their four-year period runs from the start of residence rather than from the date of the reform, so only the remainder of that period is available. Under helpsheet HS266, those who became UK resident from the 2022 to 2023 tax year onwards can use the regime from 2025 to 2026 up to and including the last tax year of their four-year period. In practice this means some people have one or two years left rather than four — and it is better to establish that before the period expires.
Temporary Repatriation Facility: the reduced rate and its deadlines
The second transitional mechanism addresses historic rather than future income. The Temporary Repatriation Facility (TRF) allows anyone who previously used the remittance basis to designate foreign amounts that arose before 6 April 2025 at a reduced rate. It runs for three tax years, and the rate is not the same in each.
| Tax year | TRF rate | Designation deadline |
|---|---|---|
| 2025 to 2026 | 12% | 31 January 2028 |
| 2026 to 2027 | 12% | 31 January 2029 |
| 2027 to 2028 | 15% | 31 January 2030 |
One detail is frequently missed: there is no need to bring funds into the UK during the TRF period in order to benefit from the reduced rate. HMRC states expressly that individuals do not have to remit their pre-6 April 2025 income and gains during the period, although they may if they choose to. The designation is made in the Self Assessment return for the relevant tax year, and the time limit is the anniversary of 31 January following the end of that year.
The second point concerns what can be designated. Alongside personal foreign income and gains from earlier years, the facility can cover amounts of uncertain source held overseas by a former remittance basis user, together with certain payments and benefits from offshore structures and trusts matched with income and gains arising before 6 April 2025. The boundaries are narrow and each category has to be tested separately, which is one reason a review is carried out before, not after, the return is filed.
Non-dom transition review
Where to start with your own position
Residence check
Your status under the statutory residence test, year by year.
FIG regime modelling
How many years of relief remain and what they cover.
TRF strategy
Which amounts to designate, and in which tax year.
Inheritance and trusts
How long-term residence changes your succession plan.
Even where the scope of the work is clear, the route through it depends on how assets are held. The next component of a review concerns property rather than income, and another transitional rule applies there.
Rebasing of foreign assets and capital gains tax
Some former remittance basis users can rebase their foreign assets: for the purposes of calculating a capital gain, the starting point becomes the value of the asset on 5 April 2017 rather than its original acquisition cost. The rationale is that no UK tax is paid on growth accumulated before that date, while the assets sat outside the UK tax perimeter.
Eligibility depends on whether the remittance basis was claimed, on the individual’s domicile status before 6 April 2025, on the asset being held personally, and on it having been held at that date. The conditions are technical and are tested asset by asset rather than across a portfolio. Where rebasing does apply, the effect can be substantial: for something bought fifteen years ago, the change in base cost moves the final tax figure materially.
It is also worth remembering that the old remittance rule has not disappeared. According to GOV.UK guidance, amounts that arose in a year when the remittance basis was claimed remain taxable in the year they are remitted to the UK. Former users of the regime therefore still have to tell HMRC when such remittances are made — and it is precisely that liability which the reduced TRF rate allows to be settled earlier and more cheaply.
Inheritance tax: long-term residence in place of domicile
For many clients the succession side of the reform matters more than income tax. From 6 April 2025, foreign assets fall within the scope of inheritance tax by reference to long-term UK residence rather than domicile. Under GOV.UK guidance, an individual is a long-term UK resident if they have been UK tax resident either for the previous ten consecutive years or for a total of ten years or more within the previous twenty.
The second element of the rule is the tail: the status does not fall away on the day of departure. How long someone stays within the inheritance tax perimeter after leaving depends on how many years of residence they accumulated.
| Years of UK residence | Years within scope after leaving |
|---|---|
| 13 or fewer | 3 |
| 14 | 4 |
| 15 | 5 |
| 16 | 6 |
| 17 | 7 |
| 18 | 8 |
| 19 | 9 |
| 20 | 10 |
A transitional rule also applies: an individual is not a long-term UK resident if, on 30 October 2024, they had neither UK domicile nor deemed domicile status. For those who did hold deemed domicile status on that date, a separate shortened tail applies on departure.
Against those rules the thresholds themselves are worth keeping in view: the nil-rate band is £325,000 and the residence nil-rate band is £175,000, both fixed until 5 April 2028. Where foreign assets enter the UK estate for the first time, those thresholds cover only a small part of the value — and that changes the whole logic of wills and inheritance planning and the structure of a will.
Arising basis, FIG regime or the TRF: which applies
The three mechanisms answer different questions, and the choice between them is rarely either-or. The FIG regime deals with current foreign income of new arrivals, the TRF with historic amounts belonging to former remittance basis users, and rebasing with the disposal of long-held property. One person may qualify for two of them, but claiming one changes the arithmetic of the other.
| Criterion | Arising basis | FIG regime | Temporary Repatriation Facility |
|---|---|---|---|
| What it applies to | Worldwide income and gains | Foreign income and gains of the first 4 years | Foreign amounts arising before 6 April 2025 |
| Who can use it | Any UK resident | New arrival after 10 years of non-residence | Former remittance basis user |
| Rate | Ordinary rates of tax | Relief on the amounts claimed | 12% or 15% depending on the year |
| Personal allowance | Retained | Lost in the year of claim | Retained |
| Time limit | None | 4 years of residence | Three tax years: 2025 to 2026, 2026 to 2027, 2027 to 2028 |
| Where it is claimed | Ordinary compliance | Self Assessment return | Self Assessment return |
This table is usually where the value of a review becomes visible. Someone with large unremitted accumulations and modest current foreign income almost always gains from the TRF and gains almost nothing from the FIG regime. For someone with a substantial overseas business and no historic accumulations the position is reversed. General advice from articles is of little use here: what is needed is a calculation on your own figures, ideally as part of international tax and estate planning rather than as an isolated exercise.
Cost and timescales
The cost of a review depends on the volume of history involved: how many tax years have to be reconstructed, how many sources of income and assets are in play, and whether trust structures are present. The parameters below are indicative by situation type; a precise fee is agreed after the initial assessment, once the volume of documents is known.
| Type of situation | What the review covers | Indicative timescale |
|---|---|---|
| Basic status check | Residence under the SRT, FIG eligibility, remaining years of relief | 1 to 2 weeks |
| Review with historic accumulations | Also an inventory of foreign amounts and TRF modelling | 3 to 5 weeks |
| Review with assets and disposals | Also the asset base and capital gains tax calculations | 4 to 6 weeks |
| Full review including structures | Also trusts, the inheritance tax perimeter and the will | 6 to 10 weeks |
The timescales above are typical rather than guaranteed: they depend on how quickly statements arrive from overseas banks and trustees, and on how complete the documentation for any structures is. The calendar matters as well. Starting in January, with days left before the filing deadline, leaves no room to choose between options — starting earlier keeps the choice open.
How a review runs: five stages
The work is sequential, with each stage building on the data produced by the last. The typical client path from first contact to ongoing monitoring is set out below.
Initial residence check and available reliefs
Collecting data on income, assets and structures
Modelling the options and choosing a strategy
Preparing and filing the Self Assessment return
Ongoing monitoring and planning your exit
The stages need not all be taken. Some clients stop after the first two, to understand the scale, and return to the modelling a year later once the asset position is settled.
Which documents are needed
How complete the documentation is determines both the timescale and the reliability of the conclusion. The minimum set for an initial assessment is small; for a full review the list grows.
For the initial assessment:
- a chronology of arrivals in and departures from the UK by tax year;
- copies of any UK tax returns filed previously;
- details of current immigration status and plans for it;
- an outline of the sources of foreign income.
For a full review, in addition:
- overseas bank and brokerage statements for the relevant years;
- documents for foreign property and other assets, with acquisition dates;
- valuations as at 5 April 2017 where rebasing is in point;
- constitutional documents for trusts and offshore companies, with trustee reports;
- details of distributions and benefits received from structures, by year;
- the current will, and details of beneficiaries and their residence.
Practical examples
Three short examples show how the same rule works differently across different histories. All are illustrative and are given to show the logic of the calculation, not as a promise of any particular outcome.
First example. An entrepreneur moved to the UK in 2023 after fifteen years in Asia and had no earlier UK residence. Most of the income comes from a business carried on entirely outside the country. The critical question is how many years of the four-year relief remain, and whether to claim it in a year when a substantial disposal of shares is planned: relieving foreign income in that year may cost more than the capital gains exemption that is given up.
Second example. A client has lived in the UK for twelve years and claimed the remittance basis throughout, accumulating significant amounts abroad. The FIG regime is unavailable: the ten-year non-residence condition is not met. What matters instead is the TRF calendar — designating amounts in 2026 to 2027 costs 12%, while deferring to 2027 to 2028 costs 15%. On a large sum, that difference runs into tens of thousands of pounds.
Third example. A family has lived in the UK for eighteen years and plans to move abroad. Here income tax is secondary: what dominates is long-term resident status, which keeps foreign assets inside the UK inheritance tax perimeter for eight years after departure. Planning in that situation starts not with returns but with a review of the will and the ownership structure.
Comparable situations from the Imperial & Legal practice appear in the client stories section, where a review of the tax picture sits alongside relocation, buying a home and settling status.
Client stories on tax matters
Tax planning for married couple relocating to UK
Madina and Yuri are a married couple from Kazakhstan. They relocated to the United Kingdom a year ago when Yuri was invited to join a project to develop educational computer games. He agreed right...
Tax planning for married couple moving to England to settle (Indefinite Leave to Remain)
Tobias and Hannah moved to the UK from Austria. The couple received a pre-settled status, which is granted to EU citizens, permitting them to relocate...
Tax planning for a foreign person when moving and buying a property in England
Pablo is originally from South America. He has been living in Britain for several years. His business involves supplying construction equipment to...
Tax planning in England for a client with an investor visa
Andy is a long-standing client of Imperial & Legal. We helped him to obtain a UK investor visa and settle in London. He is originally from South Africa, but he changes locations quite often to...
One of those clients explained why foreign receipts were the question that concerned her most when she moved.
When my husband got an interesting job offer from the UK, we immediately decided to relocate. I run an online business and can work from anywhere in the world. However, I understood that it was not so easy since I received payments from different countries and feared that I might get into trouble with tax authorities. That’s why, I decided to contact Imperial & Legal’s specialists who helped me do everything right.
Common mistakes in the transition from non-dom status
Mistakes in this area are rarely arithmetical. Almost always they are mistakes of sequence: a decision taken before the picture was assembled, or after a window had closed.
The most common is assuming the reform only affects new arrivals. For anyone resident for ten years or more the changes are often more serious, because they reach the inheritance tax perimeter and the trust structures built under the previous rules.
The second is claiming the four-year relief automatically, without pricing the allowances given up and the inability to use foreign losses in the same year. In some scenarios the relief costs more than the arising basis.
The third is deferring a decision on historic accumulations. The reduced rate is limited to three tax years, and the last of them is more expensive than the first two. Delay here is measured in percentage points.
The fourth is treating the tax position separately from UK tax residency and immigration plans. A change of status, long absences and applications for settlement all shift the year-by-year calculation, and they have to be considered together.
The fifth is leaving wills and structures untouched. Where foreign assets enter the UK estate for the first time, documents drafted around the logic of domicile start working against the intentions of whoever drafted them.
What to deal with in the current tax year
The transitional period is built so that almost every decision carries a calendar boundary. Eligibility for the four-year relief expires by reference to years of residence, not to when a claim feels convenient. The reduced rate on historic amounts runs for three tax years, and the rate is higher in the last of them. Claims under both mechanisms are made in a return, with a deadline of the anniversary of 31 January following the end of the tax year.
The practical recommendation, therefore, is to begin not with the choice of regime but with the reconstruction of the facts: how many years of residence have accumulated, which amounts arose before April 2025, what is held personally and what through a structure. On that basis the choice becomes a calculation rather than a guess. What remains is to align the tax position with wills and structures, and to keep the deadlines under review, because inheritance tax exposure continues for years after leaving the country.
Key takeaways
- From 6 April 2025 the governing factor is residence, not domicile.
- The four-year FIG regime requires ten prior years of non-UK residence.
- A FIG claim costs the personal allowance and the CGT annual exempt amount for that year.
- The reduced rate on historic amounts runs for three years: 12%, 12% and 15%.
- Funds need not be brought into the UK to use the reduced rate.
- Long-term resident status arises at ten years of residence out of the previous twenty.
- After leaving, inheritance tax exposure continues for between three and ten years.
- Foreign assets may be rebased to their value as at 5 April 2017.
