UK FIG Regime: The 4-Year Foreign Income & Gains Exemption (Post-Non-Dom)

The UK's Foreign Income and Gains (FIG) regime lets people who become UK tax resident after a long absence claim their foreign income and gains free of UK tax for their first four years of residence. It replaced the old non-domicile remittance basis, which was abolished on 6 April 2025. To qualify you must be UK resident now and have been non-resident for the previous 10 consecutive tax years, and whether you cross that residence line is decided entirely by counting days under the Statutory Residence Test.

This is the biggest change to UK personal taxation in a generation. The concept of 'domicile' no longer drives how your foreign income is taxed; residence and the clock since you last left do. That makes day-counting the foundation of the whole regime. Below is how the four-year window works, who qualifies, and where the counting gets sharp.

What changed in April 2025

For decades, individuals who were UK resident but domiciled elsewhere could elect the remittance basis: pay UK tax on UK income, but only pay tax on foreign income and gains if and when they brought ('remitted') them into the UK. From 6 April 2025 that regime is gone. The UK moved to a residence-based system where worldwide income is taxable once you're a long-term resident, with a generous on-ramp for newcomers.

• The remittance basis is abolished, domicile no longer determines how foreign income and gains are taxed.
• New arrivals get the 4-year FIG regime: foreign income and gains are exempt from UK tax for the first four tax years of residence.
• Eligibility hinges on having been non-UK-resident for the 10 tax years immediately before your first qualifying year.
• After year four (or once you lose eligibility), you're taxed on your worldwide income like any other UK resident.

Who qualifies for the 4-year FIG regime

Two conditions must both be true. First, you must become (or already be) UK tax resident in the year you claim. Second, you must have been non-resident for all 10 of the consecutive UK tax years before that first year of UK residence. The 10-year look-back is what makes this a regime for genuine newcomers and long-absent returners, not a revolving door for people who pop in and out.

The four qualifying years run from your first year of UK residence after that decade of absence. They're counted as tax years, not rolling 365-day periods. Crucially, the four years run consecutively whether or not you actually claim FIG in each one, a year spent non-resident in the middle does not pause the clock, it simply burns a year of the allowance.

How residence is decided: the Statutory Residence Test

Everything in the FIG regime turns on the word resident, and the UK defines residence through the Statutory Residence Test (SRT). The SRT runs in three stages: the automatic overseas tests (which can make you definitively non-resident), the automatic UK tests (which can make you definitively resident), and, if neither is conclusive, the sufficient ties test, which combines your days in the UK with how many connections ('ties') you have to the country.

Day counts are the spine of all three stages. For example, you're automatically non-resident if you spend fewer than 16 days in the UK in a tax year (or under 46 if you were non-resident in all three prior years). You're automatically resident if you spend 183 days or more. In between, the sufficient ties test scales the day threshold to your number of ties, so the more connections you keep, the fewer days it takes to become resident. The thresholds are tighter for leavers (UK resident in at least one of the prior three tax years) than for arrivers (not resident in any of them), as the table below shows. Treat the figures as the standard bands, always confirm the current year against HMRC's RDR3 guidance.

The 10-year non-residence clock

The 10-year look-back is where most people slip. To start the FIG regime, you must have been non-resident in each of the 10 UK tax years before your first qualifying year. A single year in which the SRT tips you over into residence, say, a stint working in London, a sabbatical, or simply too many visits to family, resets that decade. If you were resident even once in the prior 10 years, you don't qualify, and you'd wait until the gap rebuilds.

This matters enormously for returning Britons and frequent visitors. Someone who emigrated but kept flying back for a few months each year may have unknowingly stayed UK-resident under the sufficient ties test, quietly disqualifying themselves from FIG when they eventually move back. The only way to know is to count every year of presence against the SRT thresholds and tie tally.

Split-year treatment and the tie traps

The UK can split a tax year into a non-resident part and a resident part when you arrive or leave mid-year, so your foreign income before arrival isn't swept in. Split-year treatment is helpful, but it doesn't change the FIG clock: your first year of residence is still year one of four. Mismanaging the arrival date, by, say, triggering the 183-day automatic test earlier than planned, can start the four-year window before you've organized your affairs.

The 'ties' that drive the sufficient ties test are the other trap. They include a UK home you can use, a spouse or minor children resident in the UK, more than 90 days in the UK in either of the prior two years, substantive UK work, and (for leavers) spending more UK days than in any other single country. Each tie you keep lowers the day threshold that turns you resident, which can both help you qualify for FIG on arrival and accidentally restart your 10-year clock if you visit during your absence.

• Accommodation tie, a UK home available to you for a continuous 91-day period that you use.
• Family tie, a resident spouse, civil partner, or minor child.
• Work tie, substantive UK work (broadly 40+ days of three-plus hours).
• 90-day tie, more than 90 UK days in either of the two previous tax years.
• Country tie (leavers only), more UK days than in any other country that year.

What happens after the four years end

Once your four-year FIG window closes, you're taxed on your worldwide income and gains as an ordinary UK resident, foreign dividends, rental income, interest, and capital gains all become UK-taxable as they arise, regardless of whether you bring the money to the UK. There's no remittance basis to fall back on. People often pair the end of the FIG window with a planned change in residence, so it pays to model your day counts for years five and beyond well in advance.

If you also remain (or become) tax resident somewhere else, a treaty tie-breaker may decide which country has primary taxing rights. The UK's treaties generally follow the OECD model: permanent home, then centre of vital interests, then habitual abode, then nationality. As always, the analysis rests on where you actually were, your day records are the evidence.

Track UK days from the day you arrive

The FIG regime rewards precise records: the 10-year clock, the four-year window, the midnight rule, and the sliding tie thresholds all come down to days. Tax Days tracks your UK presence against the SRT thresholds, flags when a tie changes your day limit, and keeps the contemporaneous log you'd want if HMRC ever asks. Set up the UK rule and your prior-country threshold in under a minute and let the app do the counting.