UK four-year foreign income and gains regime: eligibility and claims

Eligibility & suitability

A new framework from April 2025

The four-year FIG regime began on 6 April 2025. Eligible people must have had at least ten consecutive non-UK-resident tax years before returning or arriving. The relevant clock follows UK tax years, not four years measured from the day a residence card is issued.

The relief requires claims for eligible foreign income and gains. It is not automatic merely because someone regards themselves as non-domiciled, and the former remittance-basis framework should not be used to describe a new arrival’s position. A person arriving partway through a year needs a careful residence and split-year assessment.

Identify eligible amounts rather than moving labels

Separate foreign income and gains from UK-source amounts and income from duties performed in the UK. Overseas Workday Relief has its own rules. Holding an account abroad, routing a contract through a foreign company or being paid in another currency does not itself make the income eligible.

HMRC explains that claims can involve loss of the personal allowance and capital-gains annual exempt amount. Model whether a claim makes sense for the actual year and income category. Keep the eligibility history and calculation with the return so that another adviser can follow the reasoning.

Build the claim file before arrival

Prepare the ten-year residence history, foreign asset and income inventory, trust and company relationships, and records of any historic remittance-basis amounts. Distinguish pre-arrival capital from later income and gains. An old offshore account can contain several legally different pools of money.

Agree responsibility for Self Assessment, the FIG claims and supporting work records. Tax-return filing and repayment timings should not be confused with permission to live or work in the UK. Immigration, payroll, corporate residence and inheritance tax are separate reviews.

Year five belongs in the initial plan

The window is limited: not claiming in an eligible year does not create an extra year later. Forecast the position when ordinary taxation applies, including distributions, gains and the intended length of stay. Review the inheritance-tax residence history independently.

This regime may support a sensible UK period for some international families, but it should not encourage hurried transactions without a source and anti-avoidance review. We can coordinate the arrival, operating structure and longer-term options so the implementation follows the documented plan.

The clock is residence-based and does not pause

A qualifying resident is within the first four UK tax-resident years after at least ten consecutive years of non-UK tax residence. The regime began on 6 April 2025, but moving before that date does not create a fresh four-year period: an eligible earlier arrival can claim only for the part of the original window that remains. A year spent non-resident within that window is not banked for later.

Reconstruct residence under the Statutory Residence Test, including split-year treatment, rather than treating calendar years or visa dates as tax years. A UK tax year runs from 6 April to 5 April. A late arrival can therefore consume a qualifying year with relatively little time physically in the UK. The right comparison is the actual four-tax-year window and anticipated receipts during it.

Eligible foreign income is not foreign-paid salary

HMRC identifies eligible categories including foreign dividends, overseas property-business profits, foreign interest and profits of a trade carried on wholly outside the UK. Foreign employment earnings do not qualify under this FIG relief; Overseas Workday Relief is a separate regime. A founder working in Britain cannot assume that an overseas payer or invoice makes the trade wholly overseas.

A claim is made through Self Assessment and can be selective by income or gain. Claiming also removes specified personal and capital-gains allowances and affects adjusted net income for certain family-related calculations. Model both claiming and not claiming for low-income years. Relief from UK tax does not cancel tax withheld by the foreign source country, so compare the combined outcome.

Plan the fifth year and the separate inheritance position

An eligible person can bring covered income or gains to the UK under the new regime, but historic remittance-basis funds and transitional relief have separate rules. Maintain a clear record of when income arose, which regime applied and what was claimed. Do not merge old untaxed remittance-basis funds into a new “FIG-free” account without analysis.

Inheritance tax now uses a separate long-term-residence framework. Broadly, residence in ten of the preceding twenty tax years can bring non-UK assets into scope, and a departure tail can continue for three to ten years. That clock is not the four-year FIG clock. Trusts, gifts and estate planning therefore require a separate assessment before and after a move.