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UK Foreign Income & Gains (FIG) Regime Guide 2026

Practical 2026 guide to the UK Foreign Income and Gains regime: eligibility after 10 consecutive tax years of non-UK residence, four-year relief for qualifying foreign income and gains, remittance treatment, TRF transitional rules, Overseas Workday Relief and residence-based Inheritance Tax.

FIG Regime 2026: What Changed on 6 April 2025

From 6 April 2025, the UK no longer allows UK residents to use the former remittance basis of assessment. Instead, the new Foreign Income and Gains (FIG) regime provides relief for qualifying new UK residents who have been non-UK resident for at least 10 consecutive tax years. The regime can relieve qualifying foreign income and gains arising during the first four tax years of UK residence. It is a relief regime with specific eligibility, claim and allowance consequences, rather than a universal four-year tax exemption for every overseas receipt.

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The FIG regime applies from 6 April 2025.
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The former remittance basis is no longer available for UK residents from 6 April 2025.
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A qualifying new resident must be UK tax resident under the SRT and within the first four tax years of UK residence after at least 10 consecutive tax years of non-UK residence.
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Relief is claimed for qualifying foreign income and gains arising in the relevant year.
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A FIG claim is made for each tax year in which relief is wanted.
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Qualifying foreign income and gains relieved under FIG can be brought to the UK without an additional UK tax charge merely because they are remitted.
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FIG is different from the temporary repatriation facility, which applies to certain pre-6 April 2025 foreign income and gains of former remittance-basis users.

FIG Eligibility: The 10-Year Non-Residence Condition

The central eligibility test is residence history. A person must be a UK tax resident and be within their first four years of UK residence following at least 10 consecutive tax years of non-UK residence. The relevant history is based on tax years, not a simple count of calendar days spent abroad. FIG therefore primarily targets individuals who have been outside UK tax residence for a long period before returning to the UK.

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The 10-year condition is consecutive.
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The test is based on tax residence, not domicile.
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A person who was UK resident in an intervening tax year can break the required 10-year period.
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The relevant UK residence year is still a full UK tax-residence year even where split-year treatment applies.
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A person can be eligible for FIG without being non-UK domiciled under the old rules because domicile is no longer the gateway requirement.
Requirement2026 Position
UK residenceMust be UK resident under the Statutory Residence Test.
Prior residence historyAt least 10 consecutive tax years of non-UK residence immediately before the relevant UK residence period.
FIG windowFirst 4 tax years of UK residence following the qualifying period.
ClaimMade for each relevant tax year; relief is not automatic.
Residence outside UK for only 8 yearsDoes not satisfy the 10-year condition.
Residence outside UK for 10+ consecutive yearsPotentially eligible, subject to all other FIG conditions.

What FIG Relief Actually Covers

FIG relief applies to qualifying foreign income and gains arising during a qualifying year. The individual identifies the relevant foreign income and gains and claims relief for the chosen amounts. The regime can apply to foreign investment income, foreign property income, qualifying foreign employment income and qualifying foreign gains, subject to the detailed category rules. It does not turn UK-source income or gains into exempt amounts.

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Foreign dividends can be qualifying foreign income where the statutory conditions are satisfied.
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Foreign interest can be qualifying foreign income.
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Foreign property income can qualify where it is foreign income.
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Qualifying foreign employment income can be relieved, subject to the applicable FIG and Overseas Workday Relief rules.
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Foreign chargeable gains can qualify.
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UK-source income and UK-source gains are not transformed into FIG merely because the recipient lives abroad or has recently arrived.
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The individual must identify and claim the relief rather than simply treating all overseas receipts as exempt.

FIG and Remitting Foreign Income or Gains to the UK

A major difference from the old remittance basis is that a qualifying individual who claims FIG relief is not taxed merely because the qualifying relieved foreign income or gains are subsequently brought to the UK. The relief applies to the qualifying foreign income and gains themselves. This should not, however, be confused with historical pre-6 April 2025 foreign income and gains that arose while the person was taxed under the old remittance basis. Those historical amounts remain governed by their transitional rules and may be relevant to the TRF.

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FIG relief is not the same as the old remittance basis.
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A post-6-April-2025 qualifying FIG amount does not acquire UK tax merely because it enters a UK bank account.
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Historic pre-6-April-2025 foreign income and gains remain important for former remittance-basis users.
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Mixed funds can require tracing and separate transitional analysis.
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The TRF can simplify the treatment of qualifying historical foreign income and gains for eligible former remittance-basis users.
AmountGeneral 2026 Treatment
Qualifying foreign income/gains arising from 6 April 2025 and relieved under FIGCan be remitted to the UK without UK tax arising merely because of the remittance.
Pre-6 April 2025 foreign income/gains previously subject to remittance basisRemain subject to transitional remittance rules; FIG does not simply erase the historical remittance charge.
Pre-6 April 2025 amounts designated under TRFCan receive the applicable reduced TRF tax treatment.
Ordinary capital genuinely accumulated before UK residenceTransfer itself is not automatically taxable income; its history/source must nevertheless be established.

FIG Claims Have Significant Allowance and Loss Consequences

A FIG claim is not simply a free tax election. HMRC's 2026 guidance states that a claimant loses the Personal Allowance and the CGT annual exempt amount, together with certain other allowances and tax reductions. The claimant also cannot generally claim specified foreign income or capital losses in a year in which FIG relief is claimed. These consequences need to be included in any comparison between claiming FIG and paying UK tax on an arising basis.

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Personal Allowance is lost in a year in which FIG relief is claimed.
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The CGT annual exempt amount is lost.
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Blind Person's Allowance is lost.
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Certain married-couple/civil-partner transferable allowances and reductions are lost.
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Foreign income and capital losses that fall within the relevant FIG loss restrictions cannot generally be claimed in a FIG year.
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A partial FIG claim can therefore have very different economics from an assumption of '100% tax-free foreign income'.

FIG Is Not the Same as Overseas Workday Relief

Qualifying new residents with foreign employment income can also need to consider Overseas Workday Relief (OWR). OWR is a separate relief with separate conditions and a financial limit. The fact that an employment payment is foreign does not automatically mean it is fully relieved under FIG, and FIG and OWR should be analysed together when a new UK resident continues or begins internationally mobile employment.

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OWR is separate from FIG.
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Eligible individuals can potentially claim OWR for qualifying earnings relating to overseas workdays.
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The post-2025 OWR regime has a financial limit.
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The relieved employment income does not have to remain offshore to benefit from OWR.
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Foreign employment duties and the location of work must be analysed carefully.
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The interaction between FIG, OWR and PAYE should be considered before filing.

Temporary Repatriation Facility (TRF): Who Can Use It?

The Temporary Repatriation Facility (TRF) is aimed at individuals who previously claimed the remittance basis and still have qualifying pre-6 April 2025 foreign income and gains. It is not the general mechanism for new foreign income arising after 6 April 2025. Eligible former remittance-basis users can designate qualifying historical foreign income and gains and benefit from a reduced tax rate during the three-year facility.

Key Benchmark
TRF applies for three tax years: 2025-26, 2026-27 and 2027-28.
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The reduced rate is 12% in 2025-26 and 2026-27.
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The rate increases to 15% in 2027-28.
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Only eligible former remittance-basis users can use the facility.
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The relevant foreign income and gains must fall within the pre-6-April-2025 transitional categories.
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The TRF is separate from the FIG regime.
Tax YearTRF Rate
2025-2612%
2026-2712%
2027-2815%

TRF Designation Does Not Require Immediate Remittance

The TRF is often misunderstood as a temporary window in which designated money must physically be brought to the UK. HMRC's 2026 HS264 guidance says a taxpayer does not have to remit the designated amount during the TRF period in order to benefit from the reduced tax rate, although the amount can be remitted. The designation election is made through the Residence and FIG pages of SA109.

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Designation is the key TRF election.
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The designated amount does not have to be physically remitted during the three-year TRF period.
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A taxpayer can choose to remit a designated amount.
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The TRF tax treatment is distinct from the ordinary historical remittance rules.
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The election is made through Self Assessment/SA109 where the relevant conditions apply.
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Detailed mixed-fund and trust rules can affect the amount eligible for designation.

Legacy Remittance Basis vs FIG: Correct Comparison

The former remittance basis should not be described as simply a 15-year tax-free system with a £30,000/£60,000 fee. The old regime was a choice-based system for eligible non-domiciled taxpayers with different consequences depending on residence history and remittance-basis claims. From 6 April 2025 it has been replaced for current UK residents by the arising basis plus the new FIG regime for qualifying new residents.

Key Benchmark
FIG relief is not the same as the old remittance basis.
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A post-6-April-2025 qualifying FIG amount does not acquire UK tax merely because it enters a UK bank account.
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Historic pre-6-April-2025 foreign income and gains remain important for former remittance-basis users.
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Mixed funds can require tracing and separate transitional analysis.
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The TRF can simplify the treatment of qualifying historical foreign income and gains for eligible former remittance-basis users.
FeatureFormer Remittance BasisFIG Regime from 6 April 2025
GatewayFormer domicile/remittance-basis eligibility rules10 consecutive tax years of prior non-UK residence plus current UK residence
Core mechanismForeign income/gains could be kept outside UK tax until remitted, subject to the applicable rulesQualifying foreign income/gains can be relieved during the first 4 UK-residence years
RemittanceHistorical remittance could create UK taxQualifying FIG-relieved amounts can be brought to UK without an extra UK tax charge merely on remittance
Allowance consequencesRemittance-basis claims could lose various allowancesFIG claim also loses Personal Allowance and CGT annual exempt amount
After FIG windowLegacy rules no longer apply to current yearsOrdinary arising-basis taxation generally applies to worldwide income and gains

Year 5 and the End of FIG Relief

The FIG relief window lasts for the qualifying individual's first four tax years of UK residence following the required 10 consecutive years of prior non-residence. Once the four-year period ends, the FIG relief is no longer available. The individual is then generally taxed under the ordinary arising basis on worldwide income and gains, subject to any other reliefs or special regimes that may apply to their circumstances.

Key Benchmark
The four years are consecutive tax years of UK residence.
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A year in which split-year treatment applies still needs to be analysed under the FIG counting rules.
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FIG relief cannot be simply carried forward if an individual does not claim it in an earlier qualifying year.
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Temporary non-residence can interrupt the period and produce special interactions with FIG.
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After the four-year FIG window, ordinary UK residence taxation generally applies.
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The end of FIG relief does not itself determine UK IHT status.

Residence-Based Inheritance Tax from 6 April 2025

From 6 April 2025, the UK moved from the old domicile-based framework for Inheritance Tax on foreign assets to a residence-based long-term UK residence test. An individual is generally a long-term UK resident if they have been UK resident for at least 10 of the previous 20 tax years immediately before the relevant chargeable event. Long-term UK residents can have worldwide assets within IHT, while the position for non-long-term UK residents depends on the relevant asset and the statutory situs rules.

Key Benchmark
The key IHT concept is long-term UK residence, not the old non-dom status.
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The basic test is 10 UK-resident tax years within the previous 20 tax years.
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UK-situs assets can remain within IHT regardless of whether foreign assets are within the long-term-residence worldwide scope.
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The residence test for IHT is separate from the four-year FIG regime.
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The 10/20 test must be measured immediately before the relevant chargeable event.
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Trusts have additional and more complicated IHT rules and should not be reduced to the individual rule.

IHT Residence Tail After Leaving the UK

The residence-based IHT regime does not necessarily stop applying immediately when a long-term UK resident leaves the country. A former long-term UK resident can remain within the worldwide-assets IHT regime for a tail period, generally between 3 and 10 tax years depending on the individual's prior UK residence history. HMRC gives examples where 10 to 13 UK-resident years can result in a 3-year tail, while longer histories can produce longer tail periods.

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The tail depends on prior residence history.
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It is not correct to say that global IHT exposure ends immediately on the date of departure.
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A person returning to the UK after 10 consecutive tax years of non-residence resets the relevant 10/20 residence test under the current rules.
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The IHT tail is separate from the FIG four-year period.
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The precise tail should be calculated from the statutory residence history immediately preceding departure.
Prior UK Residence HistoryIndicative Minimum Tail
10 to 13 UK-resident years3 years after leaving
14 UK-resident years4 years after leaving
15 UK-resident years5 years after leaving
16 to 19 UK-resident yearsLonger tail under the statutory scale
20 UK-resident yearsUp to 10 years after leaving

FIG, Temporary Non-Residence and Returning to the UK

A person who leaves the UK and later returns can encounter both FIG and temporary-non-residence rules. Temporary non-residence can bring certain gains and income received while away back into UK tax on return. Separately, a returning individual can potentially qualify for FIG if the person has completed the required 10 consecutive tax years of non-UK residence. HMRC's 2026 guidance specifically addresses the interaction between temporary non-residence and FIG.

Key Benchmark
Temporary non-residence and FIG are separate regimes.
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A split year on return can count as a qualifying FIG residence year.
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FIG is only available for the first four tax years of qualifying UK residence.
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Temporary non-residence can affect gains or other specified amounts arising while abroad.
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The actual departure and return history must be analysed tax year by tax year.

Practical 2026 FIG Decision Workflow

A reliable FIG analysis should begin with the UK residence history, not domicile. Establish whether the individual is UK resident, count the consecutive prior tax years of non-residence, identify the current FIG year, list the foreign income and gains, test eligibility for each item, quantify the lost allowances and losses, and then decide whether to claim FIG. Former remittance-basis users must separately test whether historical amounts fall within the TRF.

Key Benchmark
Step 1: determine UK residence under the SRT for the current tax year.
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Step 2: establish the previous 10 consecutive tax years of residence history.
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Step 3: identify which FIG year the individual is in, if any.
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Step 4: list each category of foreign income and foreign gain.
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Step 5: identify qualifying FIG amounts and non-qualifying amounts.
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Step 6: calculate the UK tax that would otherwise arise.
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Step 7: quantify the loss of Personal Allowance and CGT annual exempt amount.
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Step 8: assess foreign losses that may be unavailable in a FIG year.
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Step 9: consider Overseas Workday Relief where foreign employment income exists.
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Step 10: if a former remittance-basis user, identify pre-6-April-2025 foreign income and gains eligible for TRF.
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Step 11: calculate the TRF rate for the relevant year: 12% for 2025-26/2026-27 or 15% for 2027-28.
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Step 12: separately test the residence-based IHT position and long-term-residence tail.
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Step 13: make the appropriate SA109/FIG/TRF claims and retain supporting residence and foreign-income records.

Frequently Asked Questions (6)

The Foreign Income and Gains (FIG) regime is a UK tax-relief regime introduced from 6 April 2025. A qualifying UK resident who is within their first four years of UK residence after at least 10 consecutive tax years of non-UK residence can claim relief on qualifying foreign income and gains. It replaced the old remittance basis for current UK-resident years, but the relief is not automatic and claiming it causes the loss of the Personal Allowance and CGT annual exempt amount.

Qualifying foreign income and gains that arose from 6 April 2025 and are covered by a valid FIG claim can generally be brought into the UK without an additional UK tax charge merely because they are remitted. This does not mean that all foreign money is tax-free: pre-6-April-2025 foreign income and gains of former remittance-basis users remain subject to their transitional rules and may instead be eligible for the Temporary Repatriation Facility.

A qualifying claimant must be UK tax resident under the SRT and be within the first four tax years of UK residence following at least 10 consecutive tax years of non-UK residence. The claim is made for each relevant year and the particular foreign income or gains must satisfy the FIG rules. A person with only 8 or 9 consecutive tax years of prior non-residence does not satisfy the basic 10-year condition.

FIG relief is no longer available after the individual's first four qualifying UK-residence tax years. The person is then generally taxed under the ordinary arising basis on worldwide income and gains, subject to any other reliefs or special rules that may apply. The end of FIG relief is separate from the residence-based Inheritance Tax rules.

The TRF is a transitional facility for eligible former remittance-basis users with qualifying foreign income and gains that arose before 6 April 2025. The rate is 12% for 2025-26 and 2026-27 and 15% for 2027-28. The taxpayer makes a designation election through the SA109 residence and FIG pages. The designated amount does not have to be physically remitted during the TRF period to obtain the reduced tax treatment.

From 6 April 2025, IHT on foreign assets generally uses a long-term UK residence test rather than the former domicile-based worldwide-asset test. An individual is generally long-term UK resident if they were UK resident for at least 10 of the 20 tax years immediately before the relevant chargeable event. A person who becomes non-UK resident after building long-term UK residence can remain within the worldwide-assets IHT regime for a tail period of between 3 and 10 years depending on their previous UK residence history. UK-situs assets can remain within IHT regardless.
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2026 TAX SNAPSHOT

Standard Personal Allowance
£12,570
Standard allowance; specialist and Scottish rules can differ.
England / Wales / Northern Ireland Basic-Rate Band
£37,700
£50,270 including the standard £12,570 Personal Allowance.
4-Year FIG Regime
Maximum 4 tax years
Available to qualifying new UK residents after at least 10 years of non-UK residence.
IHT Long-Term UK Residence
10 of previous 20 years
Overseas-asset exposure can continue for 3–10 years after leaving, depending on residence history.

Summary Takeaways & Checklist

  • The FIG regime began on 6 April 2025 and provides relief for qualifying foreign income and gains during the first four tax years of qualifying UK residence.
  • Eligibility generally requires UK residence plus at least 10 consecutive tax years of prior non-UK residence.
  • A FIG claim is not automatic and has significant consequences, including loss of the Personal Allowance and CGT annual exempt amount.
  • Qualifying FIG-relieved amounts can be brought into the UK without an additional UK tax charge merely because they are remitted.
  • Pre-6-April-2025 foreign income and gains of former remittance-basis users are not converted into tax-free FIG; transitional rules and the TRF must be considered.
  • The TRF rate is 12% in 2025-26 and 2026-27 and 15% in 2027-28.
  • TRF is available only to eligible former remittance-basis users with qualifying historical foreign income and gains.
  • The TRF designation does not require the designated money to be physically remitted during the TRF period.
  • From 6 April 2025, IHT uses long-term UK residence rather than the old domicile-based worldwide-asset test.
  • The IHT worldwide-assets test generally uses 10 UK-resident years in the previous 20, with a 3-to-10-year residence tail after leaving depending on prior UK residence history.