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Now that we have come to the end of the 2025/26 tax year, we will start to see the first Foreign Income and Gains (FIG) claims being made.
What are the FIG rules?
As a recap, the new rules were introduced from 6 April 2025 for UK resident individuals. These rules have replaced the old remittance basis rules.
Under the old rules, non-domiciled individuals who were resident in the UK for tax purposes may have been eligible to make a remittance basis claim on unremitted foreign income and gains.
From 6 April 2025, UK resident individuals will be taxed on their worldwide income and gains. However, this will not apply if they meet the qualifying conditions for the new FIG rules.
Who qualifies for FIG relief?
The new rules apply to individuals in their first four years of UK residence. This is provided they have not been UK resident in any of the previous 10 tax years.
Individuals who came to the UK after 5 April 2022 may also be eligible to make a claim for one or more years from April 2025.
How does FIG relief work?
The new FIG rules allow individuals, where eligible, to claim 100% tax relief on their foreign income and/or gains in the first 4 years of being UK tax resident. This applies regardless of whether or not these funds are brought into the UK.
The cost of claiming relief under the FIG rules is:
- The loss of the personal allowance
- The loss of the capital gains tax exemption
- A requirement to report the foreign income and gains on UK Self Assessment tax returns
What happens after 4 years?
By year 5, all income and capital gains will be taxable in the UK regardless of the individual’s domicile status. Moreover, no further relief will be given on foreign income and/or gains under the FIG rules.
Rebasing of Foreign Chargeable Assets
As part of the changes, foreign assets chargeable to capital gains tax can be rebased to their market value on 5 April 2017.
This applies automatically to individuals who:
- Have claimed the remittance basis of taxation in any year from 2017/18 to 2024/25, and
- Were not UK domiciled or deemed domiciled at any time before 5 April 2025
The relief applies to disposals on or after 6 April 2025. However, this is provided the asset was not situated in the UK at any point between:
- 6 March 2024 and 5 April 2025
This effectively means that only the gain arising from 6 April 2017 will become taxable in the UK.
It is possible to elect for this automatic rebasing not to apply, for example if the actual cost would produce a lower gain or a loss.
Temporary Repatriation Facility (TRF)
One of the transitional rules available is the Temporary Repatriation Facility (TRF).
This relief is available for a fixed 3-year period to individuals who previously claimed the remittance basis. It allows them to remit pre-6 April 2025 foreign income and gains that were the subject of a remittance basis claim to the UK at a reduced rate of tax.
TRF Tax Rates
| Tax Year | Income Tax Rate |
|---|---|
| 2025/26 | 12% |
| 2026/27 | 12% |
| 2027/28 | 15% |
The pre-6 April 2025 foreign income and gains do not actually have to be remitted to the UK to benefit from the lower tax rate.
Instead, the designated amounts on which the TRF charge is paid can then be remitted in the future without incurring any further tax charges.
In order to designate an amount for the TRF charge, it must meet certain criteria.
Any income subject to the TRF must be included in the tax returns.
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Last Updated on 26 May 2026
