Every non-dom client who's moved to the North West and started looking at property here asks a version of the same question: has the 2025 reform changed anything for what I'm about to buy? The honest answer is nuanced. The reform rewired how worldwide income, gains and estates are taxed for internationally mobile people. It changed almost nothing about how a UK property purchase itself is taxed, because UK property was never inside the old sheltering regime to begin with. Knowing which parts of the old non-dom world actually moved, and which never applied to UK property at all, is what stops good planning turning into wasted effort.
What actually changed on 6 April 2025
The remittance basis, the mechanism that let a non-UK domiciled individual keep foreign income and gains out of UK tax as long as the money stayed offshore, was abolished for everyone from 6 April 2025. In its place came the Foreign Income and Gains (FIG) regime. Someone who has been non-UK tax resident for the 10 consecutive tax years immediately before becoming UK resident now gets 100% relief on foreign income and gains for their first four tax years of UK residence, with no remittance basis charge to pay and, crucially, no restriction on bringing that money into the UK during the relief period. After the four years, worldwide income and gains are taxed on the normal arising basis, the same as any other UK resident.
Why the FIG regime doesn't touch a UK property purchase
This is the point that catches people out. The FIG regime relieves foreign income and gains, meaning income and gains arising outside the UK. Rental income from a UK property, and any gain on selling one, has always been UK-source and has always been fully taxable in the UK regardless of the owner's domicile or residence status, collected historically through the Non-Resident Landlords Scheme for an owner living abroad and through the extended rules on non-resident Capital Gains Tax on UK property for a sale. None of that changed on 6 April 2025, because none of it depended on domicile or the remittance basis in the first place. Buying a rental property in Liverpool, Manchester or Cheshire is taxed exactly the same way for a new arrival on the FIG regime as for anyone else. The regime matters enormously for that person's other worldwide income and gains; it has nothing to say about the property itself.
Where the FIG regime does matter: funding the purchase
The practical relevance to a property purchase is upstream of the property, in how the deposit and any ongoing funding is sourced. Someone within their four-year FIG window can bring genuinely foreign income and gains into the UK to fund a purchase without triggering a UK tax charge on the funds themselves, something the old remittance basis would have taxed on arrival unless the funds happened to qualify for a specific relief such as Business Investment Relief. That relief still exists in transitional form for legacy pre-6 April 2025 funds, running until 5 April 2028, but for anyone newly arriving and within their FIG window, the funding route is now considerably simpler for a straightforward property purchase: the money can generally just come in.
The Temporary Repatriation Facility
For someone who used the remittance basis in earlier years and has foreign income or gains sitting offshore from before the reform, there's a separate transitional route worth knowing about. The Temporary Repatriation Facility (TRF) runs for three tax years, 2025-26 to 2027-28, and lets that pre-6 April 2025 foreign income and gains be brought into the UK at a reduced flat tax rate rather than at normal Income Tax or Capital Gains Tax rates, with the rate rising slightly in the facility's final year. For a client sitting on old offshore gains and weighing up whether to fund a UK property purchase from that pot now or later, the TRF window closing at the end of 2027-28 is a real deadline worth planning around, not just a technical footnote.
Inheritance Tax: the bigger structural change
The more significant shift for anyone planning to settle here long-term is Inheritance Tax, which moved from a domicile-based system to a residence-based one from the same date. Under the old rules, a non-dom could in principle remain outside UK IHT on worldwide assets for many years by preserving their domicile of origin abroad. Under the new rules, becoming a long-term UK resident, broadly UK resident for 10 of the previous 20 tax years, brings worldwide assets into the scope of UK IHT, and a tail period keeps someone in scope for a number of years after they leave, scaled to how long they were resident. Domicile, as a concept for IHT purposes, has effectively been retired.
What this does not change is the position on UK property specifically. UK residential property has been within the scope of UK IHT regardless of the owner's domicile since 2017, when anti-avoidance rules closed off the route of holding it through an offshore company or trust to keep it as excluded property. Anyone still holding UK property through an offshore corporate wrapper purely for IHT reasons has, in most cases, been carrying the SDLT non-resident surcharge, ATED and extra administrative cost of that structure for years without the IHT benefit it was originally built to deliver, a point worth revisiting properly, covered in more depth in our guide to offshore structures and UK property.
What this means in practice
For someone moving to the North West and buying property here, the reform is mostly good news on the funding side, foreign income and gains can usually come into the UK more freely within the four-year FIG window than the remittance basis ever allowed, and the TRF gives a limited window to bring in older offshore funds at a reduced rate. It's not good news, and not neutral, on the estate planning side: worldwide assets are now inside UK IHT sooner for anyone settling long-term, on a test based on residence that's harder to plan around than domicile ever was. And on the UK property itself, nothing has moved at all, because nothing sheltering it existed to begin with. The residence test, the FIG window, the TRF deadline and any legacy offshore structure are all worth reviewing together before a significant UK property purchase, not after.
Common questions
What replaced the non-dom remittance basis in April 2025?
The Foreign Income and Gains (FIG) regime, effective from 6 April 2025. It gives someone who has been non-UK tax resident for the 10 consecutive tax years before arriving 100% relief on foreign income and gains for their first four years of UK residence, with no remittance basis charge and no restriction on bringing that money into the UK.
Does the FIG regime shelter income or gains from UK property?
No. The FIG regime only relieves foreign, meaning non-UK source, income and gains. UK rental income and gains on UK property have always been fully taxable in the UK regardless of domicile or residence status, so buying and letting a UK property is unaffected by the reform either way.
Am I still liable for UK Inheritance Tax on my worldwide assets after the reform?
It depends on residence, not domicile, from 6 April 2025. Someone who becomes a long-term UK resident, broadly UK resident for 10 of the previous 20 tax years, is brought into UK Inheritance Tax on worldwide assets. UK property itself has been within the scope of UK Inheritance Tax regardless of domicile since anti-avoidance rules closed the offshore-structure route in 2017.
What is the Temporary Repatriation Facility?
A three-year window, covering the 2025-26 to 2027-28 tax years, letting individuals who previously used the remittance basis bring pre-6 April 2025 foreign income and gains into the UK at a reduced flat tax rate rather than normal Income Tax or Capital Gains Tax rates. It can be a useful, comparatively low-tax source of funds for someone planning a UK property purchase.
Kieran Holsgrove is a Director and Co-Founder of Grafene Accounting, the property tax specialist firm based in Liverpool. He advises property developers, investors and landlords across Merseyside, Greater Manchester, Lancashire and Cheshire on tax structuring, developer VAT, SDLT and the long-view decisions that compound over the life of a portfolio.
This article is general information, not personal tax advice, and tax rules change. Your own position depends on facts we cannot see from here — please take advice before acting on anything above.