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 Vipul Sharma, Founder
Reviewed by Preetesh Maloo, Chartered Accountant, NRI Tax Partner
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 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 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):
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.
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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, 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%, individual 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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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, but on death the India-UK estate duty convention limits UK tax to UK assets where the person's common-law domicile is India
Where it works differently
- Comparing with India
- India abolished estate duty in 1985 and charges nothing on inheritance. Whether the UK can tax the Indian flat depends on UK long-term residence AND on the person's common-law domicile.
- Two regimes, one asset.
- Establishing exposure
- From 6 April 2025 the UK test is long-term residence (UK resident for 10 of the previous 20 tax years), not deemed domicile. A long-term UK resident's overseas assets are within UK IHT on death and on lifetime transfers.
- GOV.UK, Inheritance Tax if you are a long-term UK resident: https://www.gov.uk/guidance/inheritance-tax-if-youre-a-long-term-uk-resident
- The deceased kept an Indian common-law domicile (for example intended to return to India)
- On death the India-UK estate duty convention restricts UK IHT to UK assets, even for a long-term UK resident, so the Indian flat is outside UK IHT. This does not cover lifetime gifts, and domicile is a question of fact HMRC can challenge.
- HMRC IHTM47072 and IHTM27161: the pre-1975 India convention works on common-law domicile and ignores deemed domicile.
- The person has left the UK
- Long-term UK residence generally continues for 3 to 10 tax years after leaving (3 years after 10 to 13 years of residence, rising to 10 years), so overseas assets can stay within UK IHT for that tail. Transitional exceptions apply to people non-resident in 2025-26 who do not return: someone neither UK domiciled nor deemed domiciled on 30 October 2024 will not be a long-term UK resident; someone deemed UK domiciled on that date stops being a long-term UK resident after 3 years of non-residence.
- GOV.UK long-term UK resident guidance, including the transitional rules: https://www.gov.uk/guidance/inheritance-tax-if-youre-a-long-term-uk-resident
Commonly got wrong
- There is no inheritance tax on Indian property. True in India. A long-term UK resident whose common-law domicile is not India can still face 40% UK IHT on that same property.India charges nothing. If you are a long-term UK resident, your Indian flat can face 40% UK inheritance tax above the nil-rate band, unless your common-law domicile is still India, in which case the India-UK convention limits UK tax on death to UK assets.
- The India-UK tax treaty cannot help with inheritance tax. The income-tax DTAA does not, but a separate pre-1975 India-UK estate duty convention still applies to UK IHT on death.Check common-law domicile: if it is India, the India-UK estate duty convention restricts UK IHT on death to UK assets.