The new FIG (Foreign Income and Gains) regime effective from April 2025 and its tax implications for international HNWI investors in UK property.
The UK's 200-year-old non-dom (non-domiciled) tax regime was fully replaced from April 2025. The new Foreign Income and Gains (FIG) regime exempts foreign income and capital gains from UK tax for the first 4 years of UK residency.
Key differences from the old system
- Remittance basis abolished
- 4-year "new arrival" exemption introduced
- Full worldwide income taxation from year 5 onwards
- IHT (Inheritance Tax) linked to a 10-year residence test
Practical implications for international investors
Scenario A — Newly UK-resident investor: For the first 4 years, your foreign rental and deposit income outside the UK remains outside UK tax.
Scenario B — Long-term UK resident: UK property income is taxed in the UK, but offshore structuring (Jersey, BVI LLP) remains on the table for estate planning.
SDLT surcharges still apply
The non-UK-resident SDLT surcharge of +2% remains. Corporate buyers may face an additional +15% (enveloped dwellings) charge.
How is it structured?
Every client engagement combines a solicitor and a chartered tax adviser in a bespoke structuring exercise.
For a confidential discussion of your position, get in touch.