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Expats returning to UK may see ‘tax opportunity’ from new non-dom regime

By Mark Battersby, 9 Oct 24

Expats who meet certain conditions can bring worldwide assets and income into the UK with no UK tax implications for four years

Changes to the non-domicile regime expected to be confirmed in this month’s Budget will offer unexpected tax planning opportunities for UK expats wishing to return to the UK, say accountants James Cowper Kreston.

Following announcements first suggested by the Conservative government and now scheduled to take effect from April 2025, called the Foreign Income and Gains Regime (FIG), expats who meet certain conditions can bring worldwide assets and income into the UK with no UK tax implications for four years.

FIG offers, says Amy Virk, a director in the International Private Client team at James Cowper Kreston, tax planning opportunities for the UK’s large expat community.

The proposed FIG Regime marks a major departure from the current non-domicile regime that restricts the ability to bring overseas assets and income into the UK under the remittance basis.

“If, as is widely expected, the FIG regime is confirmed on 30 October in the first Labour Budget, it will allow individuals to return to the UK and bring into the country income and assets held overseas without any tax implications for a four-year window.

“It is a generous regime and offers returning expats an attractive tax planning window. It could, for example, provide opportunities for business owners looking to realise a gain from an overseas business without incurring tax in the UK.

“To qualify, expats must have been non-UK resident for at least 10 years and re-start their UK residence status. After the four-year window, worldwide assets will fall into the UK tax landscape as normal

“The international tax landscape remains complex, and consideration will be needed in all jurisdictions where assets are held. Professional advice is a must.”

Tags: James Cowper Kreston

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International Adviser covers the global intermediary market that uses cross-border insurance, investments, banking and pension products on behalf of their high-net-worth clients. No news, articles or content may be reproduced in part or in full without express permission of International Adviser.