🇬🇧UK Tax on Worldwide Income and Gains

Concept

A UK tax resident is normally taxed on worldwide income and gains as they arise, whether or not the money is ever brought to the UK. Non-residents are generally taxed only on UK-source income, so the gateway question is always UK tax residence under the Statutory Residence Test. From 6 April 2025 the arising basis is the default for everyone resident here: the old remittance basis has gone, and holding funds offshore no longer defers or removes the charge by itself.

The 2025 reset

The non-dom regime and the remittance basis both ended on 6 April 2025. For decades a UK resident who was non-domiciled could keep foreign income and gains outside the UK net until the money was remitted; that route has closed. Residence rather than domicile now decides how foreign income and gains are taxed, and a parallel residence-based test has replaced domicile for inheritance tax. Existing residents were moved onto the arising basis, with transitional reliefs softening the change.

The four-year FIG regime

In place of the remittance basis sits the Foreign Income and Gains (FIG) regime. A qualifying new resident, someone in one of their first four years of UK residence after at least ten consecutive tax years of non-residence, can claim 100% relief on designated foreign income and gains for those four years and may bring that money to the UK freely. The relief has to be claimed year by year on the SA109 residence pages; unused years cannot be carried forward; and anyone who claims gives up the income tax personal allowance and the CGT annual exempt amount for that year.

FIG is an annual election over chosen income or chosen gains, so it can be taken for some years and not others, and for income but not for gains. It does not shelter UK-source income, and giving up the personal allowance and the annual exempt amount means a low-FIG year is not always worth claiming. Distributions from offshore trusts and certain anti-avoidance charges fall outside the relief and need separate analysis.

Transition for former remittance-basis users

Long-term residents who used the old regime have two transitional reliefs. The Temporary Repatriation Facility lets them designate foreign income and gains that arose before 6 April 2025 and remit them at a flat 12% for the 2025/26 and 2026/27 tax years, rising to 15% for 2027/28, well below the rates that would otherwise apply. Separately, anyone who claimed the remittance basis can rebase a personally held foreign asset to its 5 April 2017 market value on a later disposal, provided the asset was held on that date and the ownership and domicile conditions are met. Both reliefs reward bringing order to mixed offshore funds before the deadlines pass.

What is in scope

Foreign income covers overseas employment income, foreign dividends, interest, royalties, rental profits and most pensions. Foreign gains cover disposals of non-UK assets, with extra rules under the offshore fund regime. Cryptoassets are usually held as personal investments, and HMRC treats individuals as paying CGT on disposals (CRYPTO20050). A foreign bank, broker, company or trustee will rarely produce UK-ready figures, so the raw data still has to be rebuilt in UK concepts.

The Self Assessment architecture

The classification test

The analysis asks: is the person UK resident for the tax year; is the item income or capital; is it UK source or foreign source; is the asset UK situs or foreign situs; is a special code applicable; has foreign tax been paid; and is a relief claimed. Crypto adds situs questions because HMRC's CRYPTO22600 links exchange-token location to beneficial-owner residence for CGT.

Consequences

Foreign income and gains can be taxable even when nothing is brought to the UK. Foreign tax may reduce the UK bill through foreign tax credit relief, but the credit is never automatic and cannot exceed the UK tax on the same item. Currency conversion, mismatched foreign tax years, pooled crypto costs, fund equalisation, excess reportable income and withholding tax all shift the computation, and a non-reporting fund can turn what looks like a gain into income taxed at higher rates.

Examples

A UK resident founder selling shares in a non-UK company may have a UK CGT event even if proceeds stay offshore. A UK resident investor in an Irish ETF may need reporting-fund and excess-reportable-income analysis. A crypto investor who never cashes out to GBP can still have taxable disposals through swaps, sales or spending.

Evidence

Evidence includes annual account statements, dividend vouchers, withholding certificates, sale confirmations, acquisition-cost files, exchange-rate methodology, crypto transaction exports, rental accounts, pension statements and foreign tax assessments. The file should let the UK computation be rebuilt from source documents and reconcile with bank KYC and source-of-funds records. It also has to stand up against HMRC's CRS and FATCA data, which already shows the department most offshore accounts before any return is filed.

Planning

Planning is classification before the event: is the receipt employment, investment, trust, company or fund income; is a disposal within CGT or the offshore income gains regime; is the four-year FIG regime available; and can foreign taxes be credited here. The most valuable work usually happens before UK residence begins, when fund status, cost basis, embedded gains, crypto records and the timing of foreign tax can still be arranged.