Navigating the Foreign Income and Gains (FIG) regime: What international families need to know

The UK tax landscape for international individuals and their families has undergone significant change.

From April 2025, the longstanding remittance basis regime, the so called non doms, has been replaced by the new Foreign Income and Gains (FIG) regime, fundamentally altering how overseas income and gains are taxed.

For international individuals and families already in the UK or looking to make a move, it is crucial to understand these changes and plan accordingly to avoid unexpected tax liabilities and to maximise available reliefs.

The FIG regime

Under the FIG regime, the treatment of foreign income depends on your residency status and how long you’ve been UK resident. New arrivals to the UK may benefit from a four-year grace period where foreign income and gains can remain untaxed in the UK, provided they are not remitted. This represents a significant planning opportunity for those relocating to the UK.

However, once this period expires, or for those who don’t qualify, foreign income and gains generally become subject to UK taxation regardless of whether they are brought into the UK. This marks a departure from the previous remittance basis system where tax could be deferred indefinitely by keeping funds offshore.

The regime includes specific reporting obligations. All foreign income, gains, bank accounts, trusts, and corporate interests must be declared on your Self-Assessment Tax Return. Non-compliance can result in substantial penalties and interest charges, making proper disclosure essential.

The Temporary Repatriation Facility

Recognising the transition challenges, HMRC has introduced a Temporary Repatriation Facility (TRF) offering a limited window to bring overseas funds to the UK under favourable tax rates. This facility is specifically designed for individuals who previously used the remittance basis and have accumulated foreign income and gains offshore.

The TRF provides reduced tax rates on repatriated funds, potentially delivering significant tax savings. The facility runs from 6 April 2025 to 5 April 2028, covering three tax years. However, timing matters significantly: repatriations made in the first two years (2025/26 and 2026/27) qualify for a 12% tax rate, while those made in the final year (2027/28) face a higher 15% rate. Acting earlier therefore provides better value.

To qualify for the TRF, the overseas funds must have previously been subject to the remittance basis regime. You’ll need to meet specific conditions and complete all necessary reporting accurately.

Take action

For clients with complex international structures involving foreign trusts, companies, or investment vehicles, careful planning is essential. The interaction between the FIG regime, the TRF, and your specific circumstances requires expert analysis to ensure that unnecessary tax liabilities do not fall.

Whether you’re a long-term UK resident who previously used the remittance basis, a recent arrival navigating the four-year grace period, or someone planning to relocate to the UK, these changes demand attention. The combination of new ongoing obligations under the FIG regime and the time-limited opportunity presented by the TRF means that decisions made now could have lasting financial implications.

We can assess your eligibility for the TRF, review your foreign income and gains position, ensure compliance with reporting requirements, and structure your affairs to minimise tax liabilities while taking full advantage of available reliefs.

The window for optimal tax planning is narrow. Contact us today to ensure you don’t miss out on valuable opportunities or face unexpected liabilities under these new rules.