The FIG regime — foreign income and gains — is what replaced the remittance basis on 6 April 2025. It gives someone arriving in the UK after at least 10 consecutive tax years abroad up to four years in which designated foreign income and gains are not taxed here, whether or not the money is brought to the UK. The price is the personal allowance and the capital gains annual exempt amount, and the relief has to be claimed every year.
What changed, and for whom
From 6 April 2025 all UK residents are taxed on the arising basis on their worldwide income and gains. Domicile stopped being the organising idea. In its place sits a residence test: the regime asks how long you were non-resident before arriving, and how long you have been here since.
You are a qualifying new resident for a tax year if it is one of your first four years of UK residence following a period of at least ten consecutive tax years of non-UK residence. Members of the House of Commons and the House of Lords are excluded. The four years run consecutively from the year you become UK resident — they are not four years of your choosing, and a year in which you do not claim is a year spent.
That ten-year look-back is the condition people get wrong. It is not ten years since you last lived here in a loose sense; it is ten consecutive tax years of non-residence immediately before the arrival year. A single year of UK residence inside that window resets it.
What the relief actually gives you
HMRC's own wording is that you will not pay tax on the qualifying foreign income and gains on which you have made a claim. That is worth reading carefully, because two things follow from it:
- It applies to designated amounts, not automatically to everything. You identify the specific income and gains by source on the return; anything you do not designate is taxed on the arising basis in the ordinary way;
- Remittance is irrelevant. Unlike the old regime, bringing the money to the UK does not create a charge. This is the single biggest practical improvement for anyone who previously had to run segregated accounts;
- It is annual. A claim is made for each year separately, so a year of relief can be skipped where the arithmetic favours it — though the four-year window keeps running regardless.
The allowances you give up
Claiming costs you the personal allowance, the capital gains annual exempt amount, the blind person's allowance and the married couple's or marriage allowance. Note the scope of that: the allowances go whether you claim in respect of income only, gains only, or both. There is no partial forfeit.
For someone with substantial foreign income the trade is obviously worth making. For someone with modest foreign income and significant UK earnings it frequently is not, and the calculation has to be run both ways each year rather than assumed once on arrival.
Claiming it
The claim goes on the residence and foreign income and gains pages of the Self Assessment return — form SA109 — with the specific amounts identified by source on the relevant supplementary pages. The deadline is the anniversary of the 31 January following the end of the tax year, which gives you twelve months beyond the normal filing date.
That extra year is useful and routinely wasted. It exists because the decision often depends on figures that are not final when the return is first filed, and a claim made carelessly in January cannot always be improved on later.
The temporary repatriation facility
The FIG regime handles income and gains arising from 6 April 2025. Everything that arose before that date under the old remittance basis is dealt with separately, by the temporary repatriation facility, and the two must not be confused — pre-April-2025 amounts cannot qualify for FIG relief.
The TRF lets you designate pre-6 April 2025 foreign income and gains and pay a flat charge on them, after which they can be brought to the UK freely. It runs for three tax years only:
- 2025/26 — 12%;
- 2026/27 — 12%;
- 2027/28 — 15%, after which the facility closes on 5 April 2028.
Two features make it more useful than it first appears. The charge is a charge on capital rather than a tax on income or gains, and no foreign tax credit relief is available against it. And designated amounts do not have to be remitted during the window — designating in 2026/27 at 12% fixes the rate even if the money stays offshore for years. Designation is made in boxes 50 to 54 of SA109.
The rate for 2026/27 is 12%, the same as the first year. The step to 15% comes in 2027/28, which makes the current year the last at the lower rate and the obvious point to deal with historic balances that were always going to come onshore eventually. Our guide to the remittance basis covers how those pre-2025 pools are identified.
What to get right
Three things decide whether this works. Establish the residence history properly before anything else, because the ten-year condition is binary and an incorrect assumption about it invalidates the whole plan. Run the allowance trade-off annually rather than on arrival. And separate the pre-April-2025 pools from post-April-2025 income at the point of arrival, because the two regimes have different rules, different forms and different deadlines, and unpicking a mixed account years later is the expensive version of this work.
Note too that the four-year clock does not pause. Someone who arrives, claims for two years and then finds their affairs have changed has two years left, not four. Plan the window as a whole.
Acumon advises new UK residents and internationally mobile families through non-dom tax, private client tax and international tax work, including the SA109 pages and TRF designations — see also our guide to international tax planning. If you arrived in the UK within the last four years and have never claimed, the deadline for the earliest year is the one to check first.