The Non-Dom Sunset: Planning Your UK Tax Exit

The United Kingdom abolished the resident non-domiciled (non-dom) tax regime on 6 April 2025 and replaced it with a four-year Foreign Income and Gains (FIG) regime for new arrivers, alongside a Temporary Repatriation Facility (TRF) that runs through 5 April 2028. For long-term non-doms, the protected status that previously sheltered foreign income, foreign gains and overseas trust structures from UK taxation has ended. In 2026 the practical question for affected individuals is no longer whether to plan a UK tax exit but how, when, and where to.

This guide describes the current rules, the planning windows that remain, the destination jurisdictions that most often appear in 2026 exit plans, and the most common mistakes in the transition.

What changed in April 2025

The remittance basis was abolished. From 6 April 2025:

• New arrivers to the UK can elect into the FIG regime for the first four UK tax years of residence (counted on a strict residence basis using the Statutory Residence Test). During this window, foreign income and foreign gains are exempt from UK tax and can be remitted to the UK without charge.
• After year four, all UK residents are taxed on worldwide income and gains on an arising basis, with no shelter.
• Previously protected non-resident trusts established by non-doms before 6 April 2025 lost their protected status. UK-resident settlors are now taxed on the income and gains of these structures on an arising basis, subject to the transitional rules.
• The Temporary Repatriation Facility allows individuals who used the remittance basis in any year before 6 April 2025 to designate previously unremitted foreign income and gains and pay a flat charge (12 per cent in 2025-26, 12 per cent in 2026-27, and 15 per cent in 2027-28). Designated funds can then be brought into the UK without further charge.
• The inheritance tax (IHT) regime moved from a domicile-based to a residence-based test. Individuals who have been UK resident for at least ten of the previous twenty tax years are now long-term residents and within scope of UK IHT on worldwide assets, with a tail of three to ten years after departure.

These changes apply to all UK residents regardless of nationality. The new rules are settled law and are not currently subject to active review.

The planning question in 2026

For a long-term non-dom resident in the UK in 2026, three timelines now matter:

1. The remaining TRF window (closes 5 April 2028) for cleansing legacy unremitted funds at a discounted rate.

2. The long-term residence IHT tail: once an individual has been UK resident for ten of the previous twenty tax years, leaving the UK does not immediately end UK IHT exposure. The tail runs for between three and ten years depending on the length of prior residence.

3. The capital gains tax position on departure: the UK does not impose a general exit charge on departure, but the temporary non-residence rules apply to anyone who returns within five complete tax years. A genuine exit with no intention to return within five years is the operational threshold.

The exit plan therefore typically sequences:

• Use of the TRF window to designate legacy funds at 12 to 15 per cent
• A clean break under the Statutory Residence Test, evidenced by a definite departure date and abandonment of UK ties
• Establishment of tax residence in a new jurisdiction before or at the date of UK departure
• Management of the IHT tail through gifting, restructuring of UK situs assets, and where applicable, life insurance

The single most consequential decision in the plan is the destination jurisdiction.

Common destination jurisdictions in 2026

Among UK leavers in 2025-2026, six destinations dominate.

United Arab Emirates (Dubai or Abu Dhabi). Zero personal income tax, zero capital gains tax, zero inheritance tax. Residency available through the ten-year Golden Visa with a qualifying investment, real estate purchase or employment. UK-UAE double tax treaty is operational. Substance requirements are real: 183 days of physical presence is the cleanest evidence, though tax residence can also be established with 90 days plus close UAE ties.

Italy under the EUR 200,000 lump sum regime. A flat annual charge of EUR 200,000 (raised from EUR 100,000 in August 2024) covers all foreign-source income and gains for up to fifteen years for new tax residents who have not been Italian tax resident in nine of the previous ten years. Family members can be added at EUR 25,000 each. UK-Italy double tax treaty is operational.

Switzerland under the lump sum (forfait) regime. Available in approximately fifteen cantons. Tax is calculated on a deemed expenditure base, typically resulting in annual tax of CHF 150,000 to CHF 500,000 depending on canton and family circumstances. Available only to non-Swiss citizens who do not work in Switzerland.

Monaco. Zero personal income tax (with the exception of French citizens). Requires real residence, evidenced by accommodation and physical presence. Residency requires demonstration of financial means and a clean criminal record.

Portugal under the IFICI regime. The successor to NHR, narrower in scope, primarily attractive to those with qualifying employment or activities in research and innovation. For most UK leavers without a qualifying activity, Portugal is less attractive post-NHR than it was before 2024.

Greece under the EUR 100,000 non-dom regime. Flat annual EUR 100,000 on foreign income, available for up to fifteen years, with a qualifying EUR 500,000 investment in Greek assets. Family members can be added at EUR 20,000 each.

The right destination depends on the size and source of foreign income, family circumstances, willingness to commit to physical presence, and the appetite for European versus Gulf lifestyle.

The Temporary Repatriation Facility in practice

The TRF is the most useful single transitional measure for departing non-doms. Two practical considerations:

The 12 per cent rate applies in 2025-26 and 2026-27 and rises to 15 per cent in 2027-28. The arithmetic favours designation in the first two years, particularly for individuals who plan to bring previously untaxed foreign income into the UK or into structures that will eventually be taxed on UK residents.

Designation under the TRF is not the same as remittance. Funds can be designated and the charge paid without an immediate remittance; the designated funds can then be remitted at any subsequent time without further UK tax. This separation matters for individuals who want to lock in the lower rate now and decide later whether and when to bring funds to the UK.

Inheritance tax: the residence tail

The shift from a domicile-based to a residence-based IHT test is, for many long-term non-doms, the single most expensive element of the reform. An individual who has been UK resident for ten of the previous twenty tax years is a long-term resident and remains within scope of UK IHT on worldwide assets for three to ten years after departure, depending on the length of prior residence.

Planning typically involves:

• Lifetime gifting before departure to start the seven-year potentially exempt transfer clock
• Restructuring of UK situs assets where possible
• Life insurance to cover the IHT exposure during the tail
• Careful management of trust structures, which lost protected status in 2025

A genuine exit reduces the tail to zero only after the longest applicable tail period has expired. Returning to the UK before then resets the position.

Common mistakes

The most expensive mistake in 2026 exit planning is leaving the UK without first establishing tax residence in the new jurisdiction. A gap creates statelessness for tax purposes, exposes worldwide income to UK arising-basis taxation in the year of departure (subject to split-year treatment), and complicates the application of double tax treaties.

The second most expensive is underestimating the IHT residence tail and assuming that departure ends UK exposure. It does not.

The third is failing to use the TRF window. The discount applies for a limited period and the arithmetic of designating now and remitting later is favourable for most affected individuals.

The fourth is choosing the destination jurisdiction on lifestyle grounds without modelling the actual tax outcome. Several apparently attractive jurisdictions (Portugal post-NHR, Spain absent the Beckham law, France) are materially worse on tax than the headline marketing suggests.

Frequently asked questions

Can I still use the remittance basis if I was already claiming it? No. The remittance basis was abolished on 6 April 2025. Transitional measures (TRF, capital gains rebasing for certain assets) are available but the regime itself has ended.

Does the FIG regime apply to me if I have been in the UK for ten years? No. The FIG regime is for new arrivers in their first four years of UK residence. Long-term residents do not qualify.

Can I move to a Crown Dependency (Jersey, Guernsey, Isle of Man) and stay close to the UK? Yes, and each is a credible destination with established HNW infrastructure. The IHT residence tail still applies.

How long must I stay out of the UK? Five complete tax years to avoid the temporary non-residence rules on capital gains. Longer to fully run off the IHT residence tail.

Will the rules change again? Possible but not currently signalled. The 2025 reforms had cross-party support and the new regime is settled law.

Where to go next

For destination-specific detail, see,, and. For the citizenship questions that often sit alongside a tax exit, see complete guide to citizenship by investment 2026.

This article is general information and is not legal, tax, or financial advice. UK tax exits have significant and irreversible consequences. Always consult a UK tax advisor and a tax advisor in the destination jurisdiction before taking action.