UK Domicile, Non-Doms and the New Residence-Based System: What Changes in 2025
The non-domicile regime has undergone its most significant reform in decades. We explain what has changed, who is affected, and what planning steps to consider.
The taxation of non-UK domiciled individuals has been fundamentally reformed. From April 2025, the remittance basis of taxation — which allowed non-doms to shelter non-UK income and gains from UK tax — has been replaced with a new residence-based system.
The new regime
Under the new rules, individuals who have been UK resident for more than four years will generally be subject to UK tax on their worldwide income and gains, regardless of domicile. The first four years of UK residence continue to attract favourable treatment.
Who is affected?
- Long-term UK residents previously using the remittance basis
- Non-doms with offshore trusts and structures
- Individuals planning to come to the UK
- Those considering leaving the UK
Transitional provisions
The Government introduced a number of transitional provisions, including a Temporary Repatriation Facility (TRF) allowing previously unremitted income and gains to be brought to the UK at a reduced tax rate for a limited period.
Planning considerations
The changes require a thorough review of existing offshore structures, trust arrangements and asset bases. Planning should be undertaken urgently — particularly for those who may benefit from the TRF or who are considering a change in their UK residence position.
Newshams has extensive experience advising internationally mobile individuals and families. Contact us to discuss your position.
Frequently Asked Questions
What is the statutory residence test?+
The statutory residence test (SRT) is a set of rules used to determine whether an individual is UK resident for tax purposes. It considers days spent in the UK, connecting ties, and working time patterns.
How are non-doms taxed in the UK?+
Non-UK domiciled individuals (non-doms) have historically been able to use the remittance basis of taxation. The rules changed significantly from April 2025, replacing the domicile-based system with a residence-based one. Specialist advice is essential.
Do I need to declare foreign income in the UK?+
If you are UK resident, you may need to declare foreign income and gains. The treatment depends on your residence status and whether you use the arising or remittance basis. A Chartered Tax Adviser can guide you.
Simon Newsham CTA
Chartered Tax Adviser — Founder, Newshams Tax Advisers
Simon Newsham is a Chartered Tax Adviser (CTA) with over 30 years' experience advising businesses, high net worth individuals, law firms and accountancy practices on complex UK tax matters. He has been advising clients since 1995 and is a member of the Chartered Institute of Taxation.
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