Navigating the Changing Landscape of UK Non-Domicile Taxation

The world of taxation is often a labyrinth of regulations and reforms, and for individuals navigating the UK’s non-domicile (non-dom) regime, recent changes bring both challenges and opportunities. As of April 2025, a new four-year residence-based regime will come into effect, reshaping the taxation landscape for non-UK residents. Let’s delve into the key points of this upcoming transformation:


  • Existing non-dom rules remain until April 2025.
  • New four-year residence-based regime applies from 6 April 2025.
  • First tax returns affected will be for the year ending 5 April 2026.

 Eligibility for the New Regime

  • Individuals qualify if non-UK tax resident for at least 10 consecutive years.
  • New rules apply for first four tax years of UK residence.
  • Applicable to returning UK domiciliaries.

 Taxation of Personally Held Assets

  • Remittance basis scrapped under proposed rules.
  • Non-UK income and gains can be brought to the UK tax-free during qualification period (up to four years).
  • After initial four years, taxed on worldwide income and gains on arising basis.

 Transitional Provisions for Current Non-Doms

  • Transitional rules include 50% reduction to tax on foreign income for one year.
  • RNDs moving from remittance to arising basis on 6 April 2025 qualify for one-year tax reduction.


  • Rebasing relief introduced.
  • RNDs who have previously claimed the remittance basis of taxation, (and are neither UK domiciled nor deemed domiciled by 6 April 2025), can elect to rebase assets to their value at 5 April 2019 for disposals after 6 April 2025.

 Temporary Repatriation Facility for Two Years

  • RNDs taxed on remittance basis can elect reduced tax rate of 12% for foreign income and gains before 6 April 2025 for tax years 2025-26 and 2026-27.
  • Subsequent years taxed at usual rates.
  • Facility excludes income and gains matched with benefits from offshore trusts.

These changes mark a significant shift in the taxation of non-domiciled individuals in the UK. While they bring new considerations and complexities, they also offer opportunities for tax planning and optimization. As the implementation date approaches, individuals affected by these reforms should seek expert guidance to navigate the evolving tax landscape effectively.

Call AEL on 0207 433 6940 to discuss with our in-house tax specialist.