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uknon-domregulatory-update2025

The Non-Dom Door Shut on 6 April 2025.

TL;DR

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.

By , Founder

Reviewed by Preetesh Maloo, Chartered Accountant, NRI Tax Partner

Published 2026-04-08 7 min read ICAI-registered CAs

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 () regime. If you arrive in the UK after 6 April 2025 and you have not been UK tax-resident in any of the previous 10 consecutive 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 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

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 ():

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

  • For an 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 , 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.

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    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, 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 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 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 claims still work.** The India-UK DTAA is unchanged. Interest at 15%, individual dividends at 10%, Foreign Tax Credit in the UK for India 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. Trust can handle the Indian side, accurate with claims, past-year rectifications under , lower- certificates for upcoming property sales. Your UK accountant handles .

    Country guides mentioned

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    The exceptions that change the answer

    Where the general rule stops applying to you

    Every rule below has a carve-out, a cut-off date or a condition that flips the answer. These are the ones that decide real cases.

    Rectification window under s.154

    Right now: 4 years from the end of the financial year in which the order was passed

    Where it works differently

    The error is a missing TDS credit or a mis-picked figure
    Rectification is faster and cheaper than an appeal, and there is no fee.
    s.154 covers a mistake apparent from the record.
    The point needs argument or fresh evidence
    s.154 will not carry it. That is an appeal under s.246A.
    'Apparent from the record' excludes debatable questions.

    Commonly got wrong

    • Any wrong assessment can be rectified. Only a mistake apparent on the face of the record. A debatable issue needs an appeal.Rectification fixes obvious errors within four years. Anything arguable goes to the Commissioner (Appeals) within 30 days.

    UK inheritance tax on an NRI's Indian assets

    Right now: 40% above the nil-rate band on the worldwide estate of a long-term UK resident, Indian assets included

    Where it works differently

    Comparing with India
    India abolished estate duty in 1985 and charges nothing on inheritance. The UK charges 40% on the same Indian flat if the deceased was a long-term UK resident. 'No inheritance tax in India' is true and still incomplete.
    Two regimes, one asset.
    Establishing exposure
    From 6 April 2025 the test is LONG-TERM RESIDENCE, not domicile. Anyone advising on the old domicile test is out of date.
    Replaced alongside the non-dom abolition.
    Looking for relief
    The India-UK DTAA covers income tax. Check separately whether any estate-duty agreement applies before assuming relief exists.
    Do not assume the income-tax treaty helps.

    Commonly got wrong

    • There is no inheritance tax on Indian property. True in India. A UK-resident owner's estate can still face 40% UK IHT on that same property.India charges nothing. If you are a long-term UK resident, your worldwide estate, including the Indian flat, can face 40% UK inheritance tax above the nil-rate band.