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The UK’s New Foreign Income & Gains (FIG) Regime — and Why It Matters (Alongside the New IHT Rules)

  • Writer: Steve Thompson
    Steve Thompson
  • Feb 3
  • 4 min read

February 3, 2026


From 6 April 2025, the UK introduced the Foreign Income and Gains (FIG) regime. It replaced the old Remittance Basis and is designed to be simpler for people moving to the UK after spending a long period abroad.


At the same time, the UK also changed the way Inheritance Tax (IHT) works for internationally mobile families, moving from a domicile-based approach to a clearer residence-led framework.


This article explains what that means in plain English — and why it matters if you’re moving to (or returning to) the UK.


What is the FIG regime?

In simple terms, if you qualify, the FIG regime can give you a four-year window where certain foreign income and foreign gains can be exempt from UK tax.

A key practical point: during that period, the rules are intended to allow you to bring funds into the UK without the old “remittance basis” style complications — so long as the income/gains you’re relying on are within the FIG rules and you’ve made the required claim.


Who can qualify?

FIG is broadly aimed at people who:


  • become UK tax resident on/after 6 April 2025, and

  • have been non-UK tax resident for at least 10 consecutive tax years before they arrive, and

  • actively claim the regime in their Self Assessment tax return (each year they want to use it).


Think of this as a “welcome window” for new or returning residents who have genuinely been outside the UK tax system for a long period.


What does FIG cover?

The regime can apply to certain foreign income and foreign gains that arise within the four-year window — examples can include overseas dividends, interest, property income, and gains on overseas assets (depending on your personal situation).


It’s not always “all or nothing” — you can usually choose which foreign income/gains you want to claim relief on.


Who may not benefit from FIG?

FIG may not be helpful (or may not be available) if:


  • you don’t meet the strict 10 consecutive tax years non-residence test

  • you’ve already been UK resident for too long to be considered “new” under the rules

  • your main concern is older (pre-arrival) foreign income/gains — where other transitional rules may be more relevant.


You may hear about “TRF” and “rebasing” too

When the remittance basis ended, the UK introduced transitional measures that may help some people who were previously on the remittance basis.


Two common terms:


  • Temporary Repatriation Facility (TRF) — a time-limited opportunity (subject to conditions) that can allow certain people to bring specific foreign income/gains to the UK at reduced tax rates.

  • Rebasing (for capital gains) — another transitional concept that may apply in certain cases.


These are technical areas and very case-specific, so they’re best reviewed with a UK tax specialist alongside your broader plan.


The other major change: IHT is now linked to long-term UK residence

From 6 April 2025, IHT moved onto a residence-led footing.


Under HMRC guidance, you can be classed as a long-term UK resident if you’ve been UK tax resident for:


  • 10 consecutive years, or

  • 10 years or more out of the previous 20 tax years.


If you then leave the UK, there can be an IHT “tail” — meaning UK IHT exposure can continue for a period (up to 10 tax years, depending on residence history).


This is a big deal for internationally mobile families because it makes your residence timeline far more important in long-term estate planning.


Key client checklist/considerations

If you’re moving to the UK (or returning), these are the practical questions to work through early:


  • Will you be UK tax resident under the Statutory Residence Test (SRT)? This affects whether FIG is even on the table.

  • Have you truly been non-UK tax resident for 10 consecutive tax years? This is one of the most important “yes/no” tests for FIG.

  • What foreign income and gains do you expect in the first four years? The value of FIG depends on what will arise during that window.

  • Are you comfortable that you must claim FIG each year (via Self Assessment)? It’s not automatic — it’s an annual claim.

  • Do you understand the trade-offs? Claiming FIG can affect entitlement to certain UK tax allowances, so it’s not always the best choice for everyone.

  • What happens after the four years? Once FIG ends, you move into full UK worldwide taxation, so forward planning matters.

  • How does your longer-term UK residence history affect IHT? If you may become a long-term UK resident (10/20), you’ll want to map your exposure early, especially if you have overseas assets and family wealth planning in mind.


Closing thought

For the right person, FIG can offer a valuable four-year planning runway — but the outcome depends heavily on your residence historythe timing of income/gains, and what you intend to do after those four years.


Disclaimer: This is general information, not tax or legal advice. Individual circumstances vary and you should take advice from a suitably qualified UK tax specialist before acting.



 
 
 

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