The 2025 Abolition of the Non-Dom Regime
Written and reviewed by the Non-Dom Accountants editorial team. Last reviewed 28 July 2026.
The remittance basis and the concept of tax domicile were abolished on 6 April 2025 under the Finance Act 2025. From that date every UK resident is taxed on the arising basis on their worldwide income and gains, regardless of where they are domiciled or where the money sits.
This guide sets out what actually changed, what has taken the place of the old regime, and who feels the change most. If you are new to the UK, the replacement relief is the 4-year FIG regime, and the practical steps of settling in are covered by our work on arriving in the UK.
What Ended on 6 April 2025
Two things ended together. The remittance basis, which let non-domiciled residents keep foreign income and gains outside UK tax until the money was brought here, is gone. The status of domicile itself, which decided who could use that basis and who fell inside UK inheritance tax, no longer has any role in income tax or capital gains tax.
There is no transitional election to keep the old treatment for a current year. From 2025/26 onward, the remittance basis simply does not exist as a way to file.
The Arising Basis for Every Resident
Every UK resident is now taxed on the arising basis. That means foreign income and gains are taxed in the UK in the tax year they arise, whether or not the funds are ever remitted here.
The distinction between UK and foreign source income no longer changes when the tax is due. A resident with a foreign rental property, foreign dividends or an overseas disposal reports and pays in the same year as a UK-source equivalent.
The Reliefs That Replaced It
The arising basis is softened for recent arrivals by a time-limited relief for foreign income and gains, and by a transitional window to bring older wealth onshore at a fixed rate. Longer-standing residents keep no equivalent, so the change lands hardest on people who have been resident for many years.
For inheritance tax, a residence-based test now decides whether a worldwide estate is in scope, in place of the old domicile test.
Who the Change Affects Most
People who arrived within the last four tax years may still shelter foreign income and gains under the new relief. People who have been resident for longer move straight onto the worldwide arising basis, often for the first time.
Anyone who held funds abroad under the old rules faces a separate question about how to bring that money onshore without a disproportionate charge, which is where the transitional facility matters.
How the Transition Rules Bridge the Gap
Three transitional measures matter. A facility to designate pre-2025 foreign income and gains at a fixed rate, a rebasing option for foreign assets held by former remittance-basis users, and the closed cleansing window that ran only until 5 April 2019.
Each has its own eligibility and its own deadline, so the order in which they are used affects the total tax paid.