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A new era for non-doms: How will a rebasing election work?

Posted on 6 May 2025

Nicola Simmons

Managing Associate, Private Wealth and Tax

The new FIG regime broadly enables certain individuals to bring to the UK tax free their foreign income and gains or their FIG for the next four consecutive tax years.  For those people who have been UK tax resident for a number of years, are there any interim reliefs other than the temporary repatriation facility or the TRF that they can utilise?

Andrew Goldstone

Partner, Private Wealth and Tax

There is a way that long term residents may be able to limit their exposure to capital gains tax if they are to sell an asset which they’ve held for a long time after April.  Now, it’s a rebasing and what it means is, if the asset’s been owned for a long time then they can essentially rebase it to the April 2017 market value and that means if they sell it now, any gain from before 2017 will essentially be wiped out so it’s, you know, potentially a very helpful relief.  There are number of conditions though that you need to meet and some of them are quite strict.  The first is that you must never have been domiciled, UK domiciled or deemed domiciled after 2017 and up until 2025.  The second condition is that you must have claimed the remittance basis at some point between 2017 and 2025.  Now you actually have to have claimed it, it’s not enough that you qualified for it but didn’t need to claim it because for example your offshore income was under £2,000, you’ve got to claim it.  Now, there’ll be some people who think well I never claimed the remittance basis so it’s too late and I won’t be able to benefit from this new rebasing regime.  Not necessarily because you still can claim the remittance basis for April ’24 to ’25 right up until 31 January 2026 and it may be worth doing but remember if you’ve been in the UK a long time, you may have to pay the £30,000 or even £60,000 remittance basis charge to do so, so you’ve got to do the maths and see whether it’s worth paying that sum in order to benefit from this rebasing election. 

Nicola Simmons

Managing Associate, Private Wealth and Tax

People have used rebasing elections before.  Back in 2017, for those individuals who had been UK tax resident for fifteen of the last twenty years, they became deemed domiciled but were able to claim a rebasing election for those non-UK situs assets that as at 6 April 2017, how does this new rebasing election interact with that one?

Andrew Goldstone

Partner, Private Wealth and Tax

It seems to be a stand-alone election.  If you claimed rebasing back in 2017 then that will continue to apply and I don’t think that the, the new regime is relevant so even if you don’t fulfil the conditions of the new regime, I don’t think it matters as long as you’ve got sort of rebasing back in 2017.

Nicola Simmons

Managing Associate, Private Wealth and Tax

The new 2017 election is useful for those who have been UK tax resident for a number of years.  If you’d like to find out more about the FIG regime and the rebasing election, sign up to our non-dom hub. 

The new tax year began on 6 April, ushering in a new era for non-doms. Private Wealth and Tax Partner Andrew Goldstone and Managing Associate Nicola Simmons discuss the UK's new FIG regime, which allows tax-free use of foreign income or gains for four years. They address concerns for long-term residents who can't claim this relief, highlighting the CGT rebasing election to limit capital gains tax by resetting asset values to April 2017. Conditions apply, and this election interacts with previous rebasing rules from 2017 and 2008, offering potential benefits for those who have remained in the UK.

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