The four-year FIG regime, explained

On 6 April 2025 the remittance basis and the concept of non-domiciled status left the UK tax code. What replaced them is the foreign income and gains regime — FIG — and the change is more than a renaming. The old system asked where a person’s permanent home was, a question of intention and family history that could be argued for decades. The new one asks how many tax years they have been resident, which is a count.

That is the whole shape of it. A qualifying arrival gets a defined number of years of exemption on foreign income and gains, and then joins everyone else on the arising basis. There is no fee, no graduated charge for longer stays, and no discretion.

Who qualifies

You qualify if you become UK resident after at least 10 consecutive tax years of non-UK residence. The relief then runs for the first 4 tax years of UK residence.

Two features of that test change who is in scope compared with the old regime.

Domicile is irrelevant. A British citizen who left, spent long enough abroad and came home qualifies on exactly the same terms as someone arriving for the first time. Under the old rules that person was almost always domiciled in the UK and shut out of the remittance basis entirely.

The condition is binary and unforgiving. The years of non-residence must be consecutive, and a single year of UK residence inside the period breaks the run and restarts it. A split year is a year of UK residence for this purpose, so a partial return counts as fully as a full one.

Residence for each of those years is determined by the Statutory Residence Test, not by where you felt you lived. That means the qualification question is answered by day counts, ties and homes across a decade — a period longer than most people have kept anything resembling a record.

What it exempts

For a year in which the claim is made, qualifying foreign income and foreign gains are outside the UK charge. Employment income for duties performed abroad, foreign trading profits, dividends and interest from non-UK sources, rents from foreign property, and gains on non-UK assets all fall within the relief.

The single most important improvement on the old regime is what happens next: the money can be brought into the UK freely. The remittance basis taxed foreign income the moment it touched these shores, which produced a generation of carefully quarantined offshore accounts and a great deal of accidental taxation through debit cards. FIG has no remittance concept. Exempt is exempt, and the funds can be spent here.

UK-source income and gains are unaffected throughout, and remain taxable in the ordinary way.

What the claim costs

The relief is claimed on the Self Assessment return, and the qualifying income and gains must be identified and quantified — you cannot simply omit them. The claim carries a price: for any year in which you make it, the income tax personal allowance and the capital gains tax annual exempt amount are lost.

For a substantial foreign income that is a rounding error. For someone with modest foreign interest and a UK salary it can easily be a net loss. The claim is therefore an annual arithmetic exercise, evaluated year by year, rather than a status you adopt on arrival and forget.

How the clock runs

The 4 years run consecutively from the first tax year of UK residence following the qualifying period abroad. The window is fixed at that moment and does not pause.

This has a consequence that surprises people. If you arrive, stay two years, leave for a year and return, the years spent away are consumed by the window even though no relief was available in them. You may still claim in any remaining year within the window, but the window itself does not stretch.

Because the clock is measured in tax years running 6 April to 5 April, the date of arrival matters disproportionately. Arriving in March gives you a first residence year with only weeks left in it, and that year is one of your four. Arriving in April gives you nearly a full year for the same consumption of the window. The difference is a matter of days at a boundary, and it is the single largest planning lever in the regime.

Whether you are resident in the year of arrival at all is decided by the SRT. An arriver is automatically non-resident with no more than 45 UK midnight days; above that, residence turns on ties, and reaching 183 UK days settles it. So the question of when your window opens is, quite literally, a question of which days you spent here.

Year five

From the fifth tax year of UK residence you are taxed on the arising basis on worldwide income and gains. Nothing succeeds the relief and nothing extends it.

The transition is abrupt enough to be worth preparing for well before it arrives. Foreign portfolios that produced exempt gains become taxable on disposal. Distributions from offshore structures change character. Double tax relief, largely irrelevant during the exempt years, becomes central. Where the fifth year falls is known from the outset, which is what makes leaving the preparation to the fifth year avoidable.

Inheritance tax runs on its own, longer clock. Someone UK resident for 10 of the previous 20 tax years becomes long-term resident and is within the charge on worldwide assets, with a tail that continues for a period after leaving.

That second clock is the one people discover late. It is unrelated to the FIG window, it is counted in the same currency of resident tax years, and it turns a decision about a few days at the end of a March on whether a global estate is in charge.

Alongside FIG: overseas workday relief

Employees arriving under the new regime should read FIG together with overseas workday relief, which now runs on the same four-year eligibility and relieves earnings for duties performed outside the UK. It is subject to an annual cap and requires something FIG does not: a record of where each workday was performed, which is a different and harder record than a record of presence.

What Residay tracks

The FIG regime is a day-count problem wearing the clothes of a domicile question.

Residay counts UK midnight days on the UK tax year, so the residence status of each year in the qualifying period and each year of the window is computed on the statutory convention rather than on a calendar. It keeps residence history back through the years that matter for the consecutive non-residence condition, and flags the years that would break it. It marks where the window opens and where the fifth year falls, so the transition is a date you have rather than a date that arrives. And it labels workdays by country, which is what the accompanying relief requires.

Planning notes

• Test the qualifying period before assuming eligibility. One forgotten resident year inside the decade removes the relief entirely, and the years most often forgotten are the partial ones.
• Time the arrival against 6 April rather than the calendar. A few days either side of the tax year boundary can cost or save a full year of the window.
• Recompute the claim annually. The lost allowances make it a decision, not a status.
• Diarise the fifth year on arrival, and consider disposals and distributions against it while the exemption still applies.
• Keep the inheritance tax clock separately. It is longer, it counts the same resident years, and it does not stop when the FIG window closes.