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.
Want a senior CA to handle this for you, start to finish?
Free 15-minute call. We tell you what applies to your case, and what it takes.
Senior CA who specialises in NRI tax · we deal with the tax officer, you don't
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.
Country guides mentioned
Still have a question?
Ask our AI anything about this. It answers from our guides in plain English, and a CA takes over for your exact case.
AI guidance, not advice. Verify your exact case with a CA.
Talk to a CAWant to know what you can recover?
A DTAA specialist CA will review your situation. Free. 15 minutes.
No recovery, no fee. We only charge when money actually comes back.
Get weekly DTAA insights for UAE NRIs
Tax tips, treaty updates, recovery strategies. No spam. Unsubscribe anytime.
Join 2,000+ Indians in Dubai who get our weekly digest.
Keep reading
What is DTAA and Why Every NRI Needs to Know About It
India signed tax treaties with 90+ countries. These treaties cap how much tax India can deduct from your investments. Most NRIs have no idea they exist.
Read
Get Your Tax Residency Certificate: Country by Country
Your TRC is the one document that gets your Indian tax cut to the treaty rate. Here's how to get one from your country's tax office, with the costs and wait times.
Read
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.