
Perspectives
TAX & RESIDENCE
Non-dom reform and what it means for UK expatriates in the Gulf
The remittance basis is gone. Here is what actually changed for UK-connected individuals living and investing from the UAE.
From 6 April 2025, the UK's remittance basis of taxation was abolished and replaced with a residence-based system built around a four-year Foreign Income and Gains regime. For UK-connected individuals building a life in the UAE, this changes both what needs planning and when.
Domicile no longer does the work
Under the old rules, a non-UK-domiciled individual could shelter foreign income and gains indefinitely simply by not remitting them to the UK. Domicile status now plays almost no role in income tax and capital gains tax; UK tax residence is what matters. Anyone who arranged their affairs around domicile status rather than residence needs that position re-tested from first principles.
The four-year FIG window
New arrivals to the UK — and returners who have been non-resident for at least ten consecutive tax years — can claim full relief on foreign income and gains for their first four years of UK residence, with no requirement to keep the money offshore. It is a materially more generous regime while it lasts, but it is also strictly time-limited: there is no equivalent of the old remittance basis to fall back on once the window closes.
What this means for someone based in the UAE
For clients who are UK non-resident and intend to stay that way, day-count discipline under the Statutory Residence Test remains the primary safeguard — the reform doesn't change how UK tax residence is tested. For those planning an eventual return, the calculus has shifted: the old approach of building up untaxed offshore gains to remit later no longer has a home, and timing of any return now interacts directly with the four-year FIG clock rather than with domicile history.
The practical takeaway
Anyone whose UK tax planning was built on domicile status, or who is contemplating a return to the UK within the next few years, should have that position reviewed now rather than at the point of return. The transitional rules and temporary repatriation facility available for a limited period make early planning materially more valuable than planning done after the fact.
Thinking that applies to your circumstances.
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