🇬🇧The FIG regime

Concept

The Foreign Income and Gains regime is the post-6 April 2025 relief for qualifying new UK residents. It is a time-limited, residence-based relief, distinct from the old remittance basis it replaced. HMRC guidance on the 4-year FIG regime states that it replaced the remittance basis on 6 April 2025, and HMRC's RFIG41000 confirms that all UK residents are otherwise taxed on the arising basis on worldwide income and gains.

The rule

HMRC's RFIG41000 states that from 6 April 2025 all UK residents are taxed on the arising basis, but an individual who becomes UK resident after at least 10 consecutive tax years of non-UK residence can claim relief on eligible foreign income and gains in their first 4 years of UK residence. The qualifying-resident condition is expanded in RFIG44000, and the effect of a claim, including allowance consequences, in RFIG43000.

The test

Scope

FIG is relevant to new residents, returning UK residents after a long absence, founders with foreign assets, investors with foreign portfolios and trust beneficiaries. It is not available merely because someone is non-British, was previously non-dom, or keeps assets outside the UK. Foreign employment income runs through Overseas Workday Relief, not FIG.

Consequences

Eligible foreign income and foreign gains may be relieved from UK income tax and CGT for the claim years. The claim also removes the personal allowance and the annual exempt amount for those years and affects the use of foreign losses. UK-source income, UK gains and UK property remain taxable under ordinary rules.

Examples

A founder who becomes UK resident in 2026/27 after 12 years abroad and sells shares in a non-UK company during the 4-year period may be within FIG for the foreign gain if the conditions are met. A former long-term London resident who spent only 7 years outside the UK before returning is outside FIG even if assets and bank accounts are offshore. A UK-source consulting fee cannot be converted into FIG by invoicing through an offshore company.

Risk

The main risks are assuming eligibility without proving the 10-year history, claiming FIG on UK-source items, failing to model the loss of allowances, and confusing FIG with OWR. Trust and transfer-of-assets-abroad income can interact with FIG, but those analyses require exact attribution under HMRC's RFIG45300 and RFIG45400 guidance.

Evidence

The file should prove 10 years of non-UK residence, the first UK-resident year, split-year status, the source of each item, the foreign situs of assets, foreign taxes paid and the claim mechanics on SA109. It must remain usable after the 4-year window closes, when the same income and gains return to the arising basis.

Planning

FIG planning is strongest before UK residence begins. Asset disposals, portfolio composition, trust benefits, company distributions, foreign employment duties and foreign-tax-credit capacity should be modelled against the 4-year window. The regime is a bridge into the UK system, used deliberately year by year, not a permanent UK tax status.

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