How to Claim the FIG Regime on Your First Tax Return

The foreign income and gains (FIG) regime replaced the remittance basis from 6 April 2025. You can claim it if you are a qualifying new resident: UK tax resident in one of your first four years of UK residence after at least 10 consecutive tax years of non-UK residence (members of the Commons and Lords are excluded). Nationality and your old domicile position are irrelevant, and because the test looks back from your arrival year, people who first became UK resident in 2022/23, 2023/24 or 2024/25 can still be qualifying new residents for whatever remains of their four years. If you are not sure you qualify, run your dates through our FIG checker first.

The claim itself lives inside Self Assessment. HMRC's helpsheet HS266 confirms you make it on the SA109 pages, now renamed "Residence and foreign income and gains (FIG) regime etc", and that you make separate claims for foreign income and for foreign gains, plus a separate election if you want Overseas Workday Relief on foreign employment earnings. If you are not already registered for Self Assessment, you must register: the claim only exists inside a return.

Timing matters on two levels. The 2025/26 return is due by 31 October 2026 on paper or 31 January 2027 through software. The FIG claim itself can be made or amended up to the anniversary of the normal 31 January filing date, so 31 January 2028 for 2025/26, which gives late arrivals a window to correct their position.

One practical point catches almost everyone: the SA109 is not supported by HMRC's free online filing service. The official SA109 notes say that to submit these pages online "you'll need to purchase software from a commercial supplier, or authorise a professional agent to file your tax return on your behalf", and they specifically tell you not to submit the pages as an electronic attachment to an online return. Your realistic options are commercial software, an adviser, or paper.

On the 2025/26 form, the boxes that matter for a first FIG claim are:

• Boxes 1 to 3: your residence status, including box 3 if split-year treatment applies to your arrival year.
• Box 23: your date of arrival in the UK, with box 24 for the most recent tax year you were UK resident before that arrival, if any.
• Box 28: put an X to claim relief on foreign income under the FIG regime.
• Box 29: put an X to claim relief on foreign gains under the FIG regime.
• Boxes 40 to 49: the Overseas Workday Relief election and claim for foreign employment earnings, which box 28 does not cover.
• Boxes 50 to 53: Temporary Repatriation Facility elections and designation amounts for former remittance basis users.

Ticking a box is only the start. The SA109 notes require you to report the income or gains to be relieved "on a source by source basis" on the appropriate supplementary page: SA103F for a wholly overseas trade, SA104F for partnership shares, SA106 for foreign investment and property income, SA107 for trust and estate income, and SA108 for foreign gains. Box 28 also reroutes your entries: you must not use boxes 3 and 6 on page TR 3 of the main return, and all untaxed foreign interest and foreign dividends, whatever the amount, go on the SA106 foreign pages instead.

The claim is strictly year by year. HMRC's manual states that a claim for year 1 "will not automatically apply to years 2, 3 or 4": you claim again, and you can pick different sources, in each year you want relief. The four-year window is fixed by your first year of UK residence and keeps running whether or not you claim; unused years cannot be rolled forward. Only income and gains arising on or after 6 April 2025 can qualify (and the SA109 notes flag a narrow category of "disqualified income" that cannot be relieved at all), so 2022/23 arrivals can claim for 2025/26 only, their final qualifying year.

FIG relief is not free. HMRC's guidance on the effects of a claim is blunt: the losses below apply "regardless of whether a claim or election is made for only foreign income, only foreign gains, or only OWR". For each year you claim, you give up:

• Your income tax personal allowance (£12,570), in full, even if you only relieve a small amount of foreign interest.
• The capital gains tax annual exempt amount (£3,000).
• Blind person's allowance, the married couple's tax reductions and the transferable marriage allowance.
• Relief for foreign capital losses in the claim year, which become non-allowable.
• Loss relief for that year's overseas trade or property losses, which HMRC confirms is lost not just in the claim year but in every later year too.

That turns each year into a simple comparison: is the UK tax you save on the relieved foreign income and gains worth more than the tax cost of losing those allowances? Someone with £2,000 of foreign interest whose UK earnings still attract the personal allowance will usually be worse off claiming; someone with a large offshore bonus, a foreign property sale or substantial investment income will usually be far better off. Because the claim is annual, you can and should redo this arithmetic every year: claiming in year 1 does not commit you to claiming in year 2.

Note also that on the same principle, an Overseas Workday Relief election alone (boxes 40 and 41) costs you the same allowances, so employees relying only on OWR face the identical trade-off. For new OWR claims the relief itself is capped at the lower of 30% of qualifying employment income and £300,000, although the cap does not apply where the pre-April 2025 transitional provisions in box 43 are in point.

The single most dangerous assumption about the FIG regime is that relieved income is "exempt", so it does not need to be mentioned. The opposite is true. HMRC's manual (RFIG42100) says a claim must "include details of the foreign income or gains to be relieved" and that "the amount of relief being claimed must be quantified in the relevant tax return". It goes further: incorrectly quantifying a claim does not invalidate it, but "not quantifying a claim at all does invalidate the claim".

Read that as a chain of consequences. If you tick box 28 but leave the foreign income off the supplementary pages, you have not made a valid claim. If the claim is invalid, the income is simply taxable foreign income of a UK resident that you failed to declare, which is the classic recipe for enquiries, penalties and interest. The regime relieves tax; it does not relieve the reporting.

For the same reason, you cannot avoid filing altogether just because everything would be relieved. The relief only exists inside a return, so a qualifying new resident with entirely relieved foreign income still needs to register for Self Assessment, file the return, tick the claim boxes and set out the numbers. This is a genuine cultural shift from the remittance basis era, when unremitted foreign income could often stay off the UK return entirely: under FIG, HMRC sees everything, and the relief is applied on top.

Because the claim is quantified source by source, you need workable figures for every foreign account and asset, not a single global estimate. For a clean first FIG return, gather:

• Interest certificates or annual statements for every non-UK bank and savings account.
• Dividend statements for foreign shareholdings, and broker tax packs for investment accounts.
• Fund documentation showing whether each offshore fund has UK reporting status, which decides how its gains are taxed.
• Completion statements and cost history for any foreign property or asset disposals, with gains computed in sterling using exchange rates at acquisition and disposal.
• Evidence for your residence position: arrival date, day counts for the statutory residence test, and your residence history proving 10 consecutive non-resident years.
• Foreign tax paid on each source, since relieved income cannot also generate a UK foreign tax credit and the interaction needs checking source by source.

Day counting deserves special care in an arrival year: your split-year date and your qualifying-new-resident status both hang off the statutory residence test, and our SRT calculator will show you where you stand before anything is filed.

This is exactly the work Horizon does for first FIG returns. As a CTA-led cross-border practice we prepare the SA109 and supplementary pages, run the claim-versus-allowances arithmetic for each year, and, through our Global Compliance Manager service, keep the account-by-account records organised so years 2 to 4 are straightforward rather than a scramble.

Three complications cluster around a first FIG return, and all three are handled on the same SA109 pages.

Split-year arrival. If you arrived part-way through the year and qualify for split-year treatment (box 3), foreign income and gains arising in the overseas part of the year are generally outside UK tax anyway, so they may need no FIG claim at all. But HMRC confirms that a split year still counts as a full year of UK residence for the FIG regime, so your arrival year burns one of your four years even if you were only here for a few months. Whether to claim at all in a short arrival year, when little foreign income falls in the UK part, is one of the key first-year judgement calls.

The Temporary Repatriation Facility. FIG relief only covers income and gains arising on or after 6 April 2025, and HMRC is explicit that former remittance basis users returning after 10 years abroad cannot use FIG for their older money. Instead, pre-6 April 2025 foreign income and gains of former remittance users can be designated under the Temporary Repatriation Facility on the same SA109 (boxes 50 to 53), at a flat 12% for designations made in 2025/26 or 2026/27 returns, rising to 15% for 2027/28. Once designated and charged, those funds can be brought to the UK with no further tax.

Offshore funds. Gains on offshore funds without UK reporting status are offshore income gains, taxed as income rather than capital gains. HMRC's manual lists offshore income gains as qualifying foreign income for the FIG regime, so they can be relieved, but through the foreign income claim in box 28 and the income pages, not the box 29 gains claim on SA108. Gains on reporting funds stay within capital gains treatment and the box 29 claim. Misclassifying a fund puts the amount in the wrong claim, which risks the quantification of that source failing, so confirming each fund's reporting status is a genuine pre-filing task, not an afterthought.