The UK's Four-Year Tax Window for New Arrivals
For internationally mobile families considering a UK base, timing has always mattered.
But since April 2025, there is a specific, time-limited tax benefit for qualifying new arrivals that makes the question of *when* to move more commercially interesting than it has been for a generation.
It is called the Foreign Income and Gains regime; FIG for short.
And for families who qualify, it can be a significant factor in the overall financial case for a UK relocation.
What Changed in April 2025
Until April 2025, the UK operated a non-domicile regime, the "non-dom" remittance basis, which allowed individuals with a non-UK domicile to pay UK tax only on foreign income and gains that they brought into the UK. It was a long-standing feature of the UK tax system and a draw for internationally mobile wealth.
From 6 April 2025, that regime was replaced. In its place, the UK introduced the Foreign Income and Gains (FIG) regime: a four-year window available to qualifying new arrivals, regardless of domicile.
Under the FIG regime, a qualifying individual pays no UK tax on foreign income and gains for their first four UK tax years of residence. Those funds can also be brought into the UK freely during those four years, without triggering a UK tax charge.
After four years, the FIG period ends and the individual moves onto the standard UK residence basis — worldwide income and gains become taxable in the UK in the usual way.
Who Qualifies — The 10-Year Gate
The FIG regime is specifically designed for new arrivals, and the eligibility gate is clear: you must have been non-UK tax resident for at least 10 consecutive tax years immediately before the first year in which you claim the relief.
This means:
- It is available to someone who has lived outside the UK for the past decade and is now relocating
- It is not available to someone who has been UK tax resident within the past 10 years
- It requires becoming UK tax resident — you cannot access it while remaining offshore
The 10-year test is binary.
Either you meet it or you do not. For families who have been based outside the UK for a decade or more,. the typical profile of the HNW families this route is designed for, it is generally a straightforward question to answer.
For families with more complex histories of UK and non-UK residence, a qualified tax adviser will need to assess the position carefully.
What the Four Years Allow
For a qualifying new arrival, the FIG regime's practical effect is significant:
Foreign income is sheltered. Dividends, rental income, interest, and other income arising outside the UK are not subject to UK income tax during the four-year FIG period. This applies regardless of whether the funds are remitted to the UK.
Foreign gains are sheltered. Capital gains on non-UK assets realised during the FIG period are not subject to UK Capital Gains Tax, and can be brought into the UK without a tax charge.
Freedom to remit. Under the old non-dom remittance basis, bringing sheltered funds into the UK would trigger a tax charge. Under FIG, remittances during the four-year window are free of that charge. For families relocating and establishing a UK household, property purchase, schooling, living costs, this is a meaningful practical advantage.
What the FIG regime does not do: it does not shelter UK-source income or gains. Salary from a UK role, rental income from UK property, and gains on UK assets are all taxable in the UK in the normal way from the first day of UK residence.
What Happens After Year Four
At the end of the four-year FIG period, the individual transitions to full UK residence taxation. From that point:
- Worldwide income and gains are taxable in the UK
- Double tax treaties with the individual's country of origin will determine how foreign income and gains are treated to avoid double taxation
- Proper tax planning for the post-FIG period should be in place well before year four ends
This transition is not a cliff edge if it is planned for. Families who have used the four years to structure their affairs, with qualified UK and international tax advisers working together, will be in a significantly better position than those who have not. The FIG period is best treated as a planning window, not just a tax relief.
How the FIG Window Fits a UK Residency Route
For families structuring a UK Skilled Worker self-sponsorship route, the FIG timing question is a material part of the overall planning conversation.
The FIG clock starts from the first UK tax year of residence. For a family that becomes UK resident in, say, April 2026, the four-year window runs through to April 2030. The five-year qualifying period for ILR runs concurrently.
That means a family arriving and establishing residency promptly can benefit from the full four-year FIG window during the first four years of their qualifying residency period — giving them significant flexibility on their foreign income and gains precisely while the route is being established and the family is settling in.
The interaction between FIG eligibility, UK arrival date, UK tax year timing, and the ILR qualifying period is the kind of multi-variable planning question that a coordinated team of immigration and tax advisers needs to work through for each family's specific circumstances. Marlow Bray brings that coordination together.
It is also worth noting that the FIG regime is only one dimension of the financial case for a UK base. For families with children approaching university age, the difference between home fees and international tuition is often equally compelling — a saving that can reach well into six figures across degrees. And for families thinking about their children's long-term UK future, why children of settling parents avoid the Graduate visa countdown is a third significant factor. The most effective planning considers all three together.
Fitting It to a Relocation Plan
A few practical points for families at the planning stage:
Arrive in the right UK tax year. The UK tax year runs from 6 April to 5 April. Arriving in the UK and becoming tax resident in, say, March rather than May could cost you an entire tax year of FIG relief. Arrival timing should be part of the planning, not an afterthought.
Get professional advice on the 10-year test before you move. If there is any complexity in your UK residence history, establish the position clearly before relocation. The test looks back 10 years from the first FIG year, and any period of UK tax residence within that window can affect eligibility.
Plan the post-FIG transition from year one. The four years pass faster than families expect. Having a plan for the post-FIG period — including how foreign income and gains will be structured, and what double tax treaty positions apply — should begin at the start of the window, not at the end.
Understand that FIG requires genuine UK residence. Like home-fee university status and the ILR qualifying period, the FIG regime requires the individual to actually be UK tax resident. It is not available to someone managing their affairs from offshore with a nominal UK address. The UK has statutory residence tests that determine tax residence, and they look at days present, ties to the UK, and other factors. A qualified adviser will assess the position for your specific circumstances.
What to Do Next
The FIG regime is a time-limited opportunity for qualifying families. The window is available to new arrivals — which means it rewards those who plan ahead and act in the right tax year.
Marlow Bray coordinates immigration and relocation planning alongside qualified tax advisers to ensure families arrive in the UK in the right way, at the right time, with the right structure in place.
Book a discovery call to start mapping your family's timeline.
