The UK Non-Dom Regime Has Ended: What Changed in April 2025 and What Wealthy Families Weigh

As of 6 November 2026.

The short answer. The UK's non-domicile regime for income and gains ended on 6 April 2025. According to HMRC's guidance, a four-year foreign income and gains (FIG) regime replaced the remittance basis from that date, and inheritance tax moved from a domicile test to one based on long-term UK residence.

What changed on 6 April 2025

Source: HMRC guidance on GOV.UK, "Check if you can claim the 4-year foreign income and gains regime" and "Inheritance Tax if you're a long-term UK resident".

The four-year FIG regime

HMRC's guidance says the regime is only available to a qualifying resident. That is someone who is UK tax resident under the statutory residence test and is still within their first four years as a UK tax resident, following at least 10 consecutive tax years as a non-UK tax resident. The guidance says eligible foreign income includes the profits of a trade carried on wholly outside the UK, the profits of an overseas property business, dividends from non-UK resident companies, and interest such as that on a foreign bank account. It links to separate guidance on foreign capital gains. It says foreign earnings and foreign specific employment income are excluded.

For people whose four-year period began before 6 April 2025, HMRC says the regime can be used from the 2025 to 2026 tax year.

Inheritance tax: the long-term resident test

HMRC's guidance says a person is a long-term UK resident in a tax year if they have been UK tax resident for at least 10 of the previous 20 tax years. The guidance says the new rules replace the domicile and deemed domicile rules from 6 April 2025.

The guidance also describes a "tail" after someone leaves the UK. It says the tail can last up to 10 tax years after leaving, and is shorter for people who have not lived in the UK for all of the previous 20 years. HMRC's guidance sets out how the length of the tail depends on the years of UK residence, and anyone affected should read it in full or take professional advice. HMRC adds that Inheritance Tax will be charged on any overseas assets in a trust that a person has set up or added to, even where they were not a long-term UK resident at the time.

What the migration data shows

Henley & Partners' Private Wealth Migration Report 2026, published on 16 June 2026, rates the UK 68.3 out of 100 on its Wealth Mobility Competitiveness Score and places it in a group it calls "under pressure". Henley reports that applications from people with a UK address rose by 15% between 2024 and 2025, and that foreign nationals account for 53% of applications from UK addresses so far in 2026. Henley's figures cover applications it received and indicate broad trends rather than exact counts. Our full guide to the report sets out the scores for every country it names.

Frequently asked questions

When did the UK non-dom regime end?

On 6 April 2025, according to HMRC. The four-year FIG regime replaced the remittance basis from that date.

Who can claim the four-year FIG regime?

HMRC says a qualifying resident: someone who is UK tax resident under the statutory residence test, within their first four years as a UK tax resident, after at least 10 consecutive tax years as a non-UK tax resident.

What is the long-term UK resident test for inheritance tax?

HMRC says a person is a long-term UK resident in a tax year if they have been UK tax resident for at least 10 of the previous 20 tax years.

How long does UK inheritance tax exposure last after leaving?

HMRC says the tail can last up to 10 tax years after leaving the UK, and is shorter for people with fewer years of UK residence. The exact length depends on the individual's residence history.

Questions to put to a qualified adviser

• How many tax years of UK residence do I have in the previous 20, and when would I stop being a long-term resident?
• Do I meet the 10 consecutive tax years of non-UK residence condition for the four-year FIG regime?
• How would any trust I have set up or added to be treated?
• How do the tax rules of the country I might move to interact with the UK tail?

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Sources: GOV.UK: Check if you can claim the 4-year foreign income and gains regime; GOV.UK: Inheritance Tax if you're a long-term UK resident; Henley & Partners press release, 16 June 2026.

This article is general information and does not constitute legal, financial or tax advice. UK tax rules are complex and individual circumstances differ; speak to a qualified UK tax adviser.