The remittance basis is gone — what replaces it for UAE residents

FIG relief, temporary repatriation facilities and the practical planning window before the old rules close for good.

Anyone who spent years structuring around the remittance basis now has to work with a different set of tools. The mechanics have changed, but the underlying need — keeping foreign income and gains outside UK tax where legitimately possible — has not gone away.

The Temporary Repatriation Facility

For those who built up unremitted foreign income and gains under the old rules, a Temporary Repatriation Facility allows that historic pool to be brought to the UK at a reduced flat rate for a limited window. For clients sitting on years of accumulated offshore gains, working out whether and when to use the TRF is often the single highest-value decision in this transition — it is time-limited and, once the window closes, the historic pool reverts to being taxed at standard rates on remittance in the usual way.

Trusts need a fresh look

Offshore trusts settled by non-doms under the old regime often relied on protections that no longer exist in the same form. Settlors and beneficiaries who are UK resident need their trust structures reviewed against the new rules specifically — what was a sound structure in 2023 is not automatically one now, and the review needs to happen before a distribution or a UK return, not after.

Inheritance tax has moved onto residence too

Alongside income and gains, UK inheritance tax has shifted from a domicile-based test to a residence-based one, with long-term UK residents brought into scope on worldwide assets after a set number of resident years, and a tail period after leaving. For UAE-based families with UK-resident members, or with a return to the UK under consideration, this changes the estate planning conversation as much as the income tax one.

Timing is the whole game now

Where the old system rewarded patience — leave it offshore indefinitely — the new one rewards sequencing: using the four-year FIG window at the right point in a UK stay, deciding on the TRF before its window closes, and reviewing trust and estate structures ahead of any change in residence rather than in response to one.

Thinking that applies to your circumstances.

Speak with a partner