Concept
UK tax is not citizenship-based. A British passport does not create a U.S.-style worldwide net. UK exposure starts with residence, then source, situs, company and trust connections, and — for inheritance tax — long-term residence. For an internationally mobile founder, investor or family it is a legal system to be modelled, not a relocation lifestyle checklist.
The post-6 April 2025 frame is decisive. HMRC states in the Residence and FIG Regime Manual that from 6 April 2025 all UK residents are taxed on the arising basis on worldwide income and gains, subject to the new Foreign Income and Gains (FIG) regime for qualifying new residents. The old non-dom remittance basis survives only for pre-6 April 2025 pools, transitional designations and legacy trust analysis.
This page is the map. Each section states the rule and links to the detailed page where the modelling actually happens — UK residence, the treaty position, trust attribution, company residence and IHT exposure all turn on facts and documents.
Residence
The Statutory Residence Test
Everything starts with the Statutory Residence Test (SRT): the automatic overseas tests first, then the automatic UK tests, then the sufficient ties test. 183 or more UK days make a person UK resident with no further analysis. Below that, residence is a function of days and ties (family, accommodation, work, 90-day and country ties), which is why a move has to be counted, not assumed.
Split-year treatment
Split-year treatment is not a separate status and not a planning toggle — it applies only where one of the statutory split-year cases is met, dividing a tax year into a UK part and an overseas part. Detail in UK tax residence.
Worldwide income and the FIG regime
Who qualifies
A UK resident is normally taxed on worldwide income and gains as they arise. A qualifying new resident — broadly, UK resident after at least 10 consecutive non-resident tax years — may claim the 4-year foreign income and gains regime for eligible foreign income and gains in their first four UK tax years.
What FIG covers, and Overseas Workday Relief
FIG is a claim, made year by year, and it is not a remittance rule: it relieves eligible foreign income and gains regardless of whether the money is brought to the UK. Foreign employment income runs through Overseas Workday Relief (OWR) for the same four-year window — capped at the lower of £300,000 or 30% of qualifying employment income — not on the assumption that all foreign salary is automatically relieved. See worldwide income and gains, the FIG regime and overseas workday relief.
Transitional rules for former non-doms
Separating pre-6 April 2025 pools
Former remittance-basis users must separate post-6 April 2025 income and gains from historical pools. The old money does not disappear; it keeps its remittance character and has to be tracked, not merged with arising-basis income. See HMRC's HS264 helpsheet.
The Temporary Repatriation Facility
HMRC's TRF manual treats the Temporary Repatriation Facility (TRF) as a separate designation regime for pre-6 April 2025 foreign income and gains: a flat 12% for designations in the 2025/26 and 2026/27 tax years, then 15% in 2027/28. Designated funds can then be brought to the UK with no further charge — against the up-to-45% that a normal remittance could otherwise attract. It is a window, with filing deadlines, not a standing relief. Detail in the remittance basis after 2025 and non-dom changes from 2025.
Companies, trusts and funds
UK residence reaches through structures — being non-UK is not the same as being out of scope.
Foreign companies
A non-UK company managed and controlled from the UK can become UK tax resident, and even where it is not, the transfer-of-assets-abroad rules and other anti-avoidance provisions can attribute its income to a UK-resident individual. Board governance and where decisions are really taken matter more than the place of incorporation. See foreign companies.
Trusts
A non-resident trust can attribute income and gains to a UK-resident settlor or beneficiary, and the 2025 reforms changed how settlor-interested and excluded-property trusts are treated. See trusts and inheritance tax.
Offshore funds
A non-reporting offshore fund can convert what looks like a capital gain into an "offshore income gain" taxed at income rates — a classic, avoidable trap in a relocating investor's portfolio. See offshore funds.
Treaties and foreign tax credit
Dual residence is common. A treaty can allocate residence and limit UK taxing rights, but HMRC's dual residence manual (INTM154020) confirms that treaty non-residence does not delete domestic UK residence or its filing duties. Relief for foreign tax runs through credit or treaty, and has to be claimed and evidenced. See foreign tax credit and treaties.
Inheritance tax
The long-term resident test
From 6 April 2025 inheritance tax is residence-based, not domicile-based. HMRC's long-term UK resident guidance explains that a person UK resident for at least 10 of the previous 20 tax years is a long-term resident, within IHT on worldwide assets.
The tail, and UK-situs assets
Long-term resident status does not end the day a person leaves: a tail of between three and ten years keeps worldwide assets within IHT after departure, scaled to how long the person was resident. UK-situs assets (UK real estate above all) are always in scope, long-term resident or not. Detail in trusts and inheritance tax.
Compliance and data
The UK rewards a defensible file. CRS and FATCA data reach HMRC and must match Self Assessment; a family office needs an ownership map, source-of-funds records and a document trail; an HMRC enquiry tests the evidence, not the label. See CRS, FATCA and HMRC data, family office records and HMRC enquiries and cleanup.
Arriving and leaving
Before arrival
SRT modelling, FIG and OWR eligibility, portfolio design (watch non-reporting funds and latent gains), trust review and rebasing questions, company governance and an IHT projection — done before the residence clock starts.
While resident
Annual SRT day-counting, FIG claims while the four-year window is open, TRF designation decisions within the deadlines, and keeping the CRS/source-of-funds file current.
On departure
Split-year treatment, the temporary non-residence rules (which can pull gains and certain income back into charge if the absence is too short), and the UK property and IHT tail. See planning before UK residence and leaving the UK.
Common pitfalls
"The UK has no more non-dom rules" is the most expensive simplification of 2025. The reality is narrower and more demanding: the remittance basis is gone for new income, but old pools, the TRF window, trust transitions and the new residence-based IHT all run in parallel, each on its own clock. Two dates decide most outcomes — the residence start date and the end of the four-year FIG window — and both are set by facts that are easy to model in advance and impossible to fix afterwards. A British passport is not US-style worldwide taxation; but "non-resident for treaty purposes" is not the same as "no UK filing", and "I left the UK" is not the same as "out of IHT".
Q&A
Residence and the FIG regime
Is UK tax based on citizenship?
No. UK citizenship is not the equivalent of U.S. citizenship-based taxation. UK exposure turns on residence, UK source, UK situs, UK property, company and trust connections, and long-term residence for inheritance tax.
Did the non-dom regime survive after 6 April 2025?
Not as the default for new foreign income and gains. The remittance basis was replaced by the FIG regime for qualifying new residents, with transitional rules for pre-6 April 2025 pools and the Temporary Repatriation Facility.
Is FIG the same as the remittance basis?
No. FIG is a time-limited, residence-based relief for eligible foreign income and gains in the first four UK tax years. It is not a rule that taxes foreign income only when it is remitted to the UK.
Who counts as a qualifying new resident?
Broadly, someone who becomes UK resident after at least 10 consecutive tax years of non-residence. That person can claim FIG for their first four UK tax years.
How does Overseas Workday Relief work now?
OWR relieves the foreign-workday portion of employment income during the four-year FIG window, capped at the lower of £300,000 or 30% of qualifying employment income — it is not an automatic exemption of all foreign salary.
Transition and the TRF
What are the TRF rates and deadlines?
12% for designations made in the 2025/26 and 2026/27 tax years, then 15% in 2027/28. Designated pre-2025 funds can then be remitted with no further charge. It is a closing window with Self Assessment deadlines, not a permanent relief.
Structures
Can a foreign company be caught by UK tax?
Yes. If it is centrally managed and controlled from the UK it can be UK resident, and anti-avoidance rules such as transfer of assets abroad can attribute its income to a UK-resident individual regardless of incorporation.
Inheritance tax and leaving
Can a person be UK resident and treaty resident elsewhere?
Yes. Dual domestic residence is common. A treaty may allocate residence for treaty purposes and limit UK taxing rights, while UK domestic filing duties remain.
When does worldwide inheritance tax exposure start?
After long-term residence: UK resident for at least 10 of the previous 20 tax years. UK-situs assets are always within IHT; long-term residence extends it to worldwide assets, with a tail of three to ten years after departure.
Does leaving the UK end my exposure immediately?
No. Temporary non-residence can claw back gains and certain income if the absence is short, and the IHT tail keeps worldwide assets in scope for several years. Departure is planned, not instant.
Related
- UK tax residence
- Worldwide income and gains
- The FIG regime
- Overseas workday relief
- The remittance basis after 2025
- Non-dom changes from 2025
- Foreign companies
- Trusts and inheritance tax
- Offshore funds
- Foreign tax credit and treaties
- CRS, FATCA and HMRC data
- Family office records
- HMRC enquiries and cleanup
- Planning before UK residence
- Leaving the UK
Last reviewed: 5 June 2026
Last reviewed: 5 June 2026