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uknon-domregulatory-update2025

The Non-Dom Door Shut on 6 April 2025.

If you used the remittance basis to shelter Indian income, that era is over. Four years of new-arrival relief. A 12% temporary repatriation window. An inheritance tax clock that now runs on residence, not domicile. Here's what to do.

TrustNRI Team 2026-04-08 7 min read

What changed on 6 April 2025

The UK non-domiciled tax regime — the rule that let long-term UK residents avoid UK tax on foreign income as long as they didn't remit it — was abolished from 6 April 2025.


In its place: the Foreign Income and Gains (FIG) regime. If you arrive in the UK after 6 April 2025 and you've been non-UK resident for 10 of the previous 10 tax years, you get 4 years of full exemption on foreign income and gains — no remittance basis charge, no claim needed.


After those 4 years? You pay UK tax on worldwide income as it arises. Every year. Your NRE FD interest, your Indian mutual fund redemptions, your Mumbai rental income — all reportable, all taxable.


For existing long-term UK residents who were using the remittance basis, the protection is gone. From 2025-26 onwards, they pay UK tax on Indian income the year it's earned, regardless of whether they bring it to the UK.

The Temporary Repatriation Facility — a 12% window

HMRC knows a lot of non-doms are sitting on pre-2025 foreign income and gains that were sheltered under the old regime. They're offering a deal: bring that money to the UK now, at a flat rate, and clear the slate.


The Temporary Repatriation Facility (TRF):

  • 2025-26: 12% flat rate
  • 2026-27: 12% flat rate
  • 2027-28: 15% flat rate

  • For an NRI who spent 15 years in the UK and never remitted their Indian dividend income, this is the cleanest way to bring accumulated wealth into the UK banking system without a 45% income tax hit.


    To use the TRF, you elect on your UK Self Assessment return and pay the flat rate on the repatriated amount. There's a specific mechanism for pre-2025 accumulated foreign income and gains. Worth getting a UK tax advisor to run the numbers before the end of 2025-26 tax year.

    Inheritance tax is now residence-based

    The biggest change most UK Indians haven't noticed yet. And the one that bites hardest.


    Under the old regime, UK inheritance tax (IHT) applied to your worldwide estate only if you were UK-domiciled. If you were long-term UK-resident but still Indian-domiciled, your Indian assets — family property in Pune, a plot in Bengaluru, inherited land in Kerala — were outside the IHT net.


    From 6 April 2025, IHT is residence-based. Once you've been UK-resident for 10 of the last 20 tax years, your worldwide estate is in the UK IHT net. That includes Indian ancestral property, Indian company shares, Indian bank balances, everything.


    UK IHT is 40% above the nil-rate band (£325,000 for most people). If you die owning a ₹5 crore flat in Mumbai and you've been UK-resident for 12 years, HMRC wants 40% of ₹5 crore minus exemptions.


    There's a 10-year "tail" rule: even if you leave the UK, the residence-based IHT follows you for 10 years after departure. So a British Indian thinking of retiring to India in 2027 is still in the UK IHT net until 2037.

    What you need to do

    **If you've been UK-resident under 10 years:** No immediate IHT exposure. But check the FIG regime applicability and whether you need to register for Self Assessment if your foreign income is now UK-taxable.


    **If you've been UK-resident 10+ years:** You are now in the IHT net. Talk to a UK estate planner about trust structures, insurance, or gifting strategies. Time-sensitive.


    **If you had pre-2025 accumulated Indian income under remittance basis:** The TRF window is open. A 12% flat rate in 2025-26 is better than paying 45% UK income tax when you eventually bring the money across. Model the numbers.


    **If you have Indian ancestral property:** Get a proper valuation. The IHT calculation will need it. Plan for liquidity — your heirs shouldn't have to sell Indian property in a rush to pay a UK tax bill.


    **Existing DTAA claims still work.** The India-UK DTAA is unchanged. Interest at 15%, dividends at 10%, Foreign Tax Credit in the UK for India TDS paid. What's changed is the UK side — the remittance-basis shield is gone, and the IHT net is wider.


    If your India-side filing was sloppy in the non-dom years (you assumed nothing needed reporting in the UK), this is the moment to clean it up. TrustNRI can handle the Indian side — accurate ITR with DTAA claims, past-year rectifications under Section 154, Form 13 lower-TDS certificates for upcoming property sales. Your UK accountant handles HMRC.

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