HorizonUK Tax Solutions

The First FIG Filing Season: Your 2025/26 Return Is Due 31 January 2027

The first FIG filing season is open now: 2025/26 was the first tax year of the foreign income and gains regime, the returns that carry the first ever FIG claims can be filed today, and the online deadline is 31 January 2027. Nobody, anywhere, has been through this before. The claim boxes are new, the quantification requirement is new, and HMRC's manual is explicit that a claim which is not quantified at all is invalid (RFIG42100, HMRC). A first-of-its-kind return with an invalid claim is not a small problem: it means the foreign income you thought was relieved is simply undeclared income of a UK resident.

The deadlines are closer than January suggests. If you arrived in 2025/26 and have never filed a UK return, you must register for Self Assessment by 5 October 2026 (GOV.UK). Paper returns must reach HMRC by 31 October 2026, and the SA109 residence pages that carry the claim cannot go through HMRC's free online service at all, so the filing route needs deciding early (GOV.UK). And for many first-time filers, 31 January 2027 brings not one bill but one and a half: the 2025/26 balance plus a first payment on account for 2026/27.

This guide sets out the whole season: why first-year FIG returns deserve extra care, every deadline between now and January, what to gather this month, how split-year arrival interacts with the claim, and a month-by-month preparation timeline. It is written by Horizon UK Tax Solutions, a Chartered Tax Adviser practice that specialises in exactly these returns, on fixed fees agreed upfront. If you take one thing from it: instruct now, not in January.

Written by Jordan Onraet-Wells, Founder & Chartered Tax Adviser (CTA). Published 8 August 2026. Last reviewed 8 August 2026.

Key takeaways

  • 2025/26 was the first year of the FIG regime, so the returns due by 31 January 2027 are the first FIG claims ever filed; there is no precedent and no second chance to make a tidy first impression with HMRC.
  • If you have never filed a UK return, you must register for Self Assessment by 5 October 2026 for the 2025/26 year; GOV.UK gives no fixed timescale for your UTR to arrive, so register in weeks, not January.
  • Paper returns are due 31 October 2026 and online returns 31 January 2027, but the SA109 pages carrying the claim cannot be filed through HMRC's free online service, so you need commercial software or an agent for the online route.
  • The claim is made on the SA109, box 28 for foreign income and box 29 for foreign gains, and every relieved amount must be quantified source by source on the SA106 or SA108; an unquantified claim is invalid.
  • A split year of arrival in 2025/26 still supports a FIG claim, including on qualifying income and gains from the overseas part, but it burns a full year of your four-year window.
  • If your 2025/26 bill tops £1,000 and less than 80% of your tax is collected at source, 31 January 2027 also triggers a first payment on account for 2026/27 of half that bill, so budget for 150% of the year's tax.
  • Claiming costs your £12,570 Personal Allowance and the £3,000 CGT annual exempt amount for the year, so the claim-or-not arithmetic should be run in the autumn, not discovered in January.
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Why this season is a genuine first

The FIG regime took effect on 6 April 2025, replacing the remittance basis for new arrivers. Its first tax year, 2025/26, ended on 5 April 2026, which means the Self Assessment returns being prepared right now are the first returns in history to carry a FIG claim. The 2025/26 edition of helpsheet HS266 confirms the mechanics: you tick box 28 on the SA109 for foreign income, box 29 for foreign gains, and you must claim for each amount of foreign income, from each source, that you want relieved, reporting dividends and interest on the SA106 foreign pages and each qualifying gain on the SA108 (HS266, GOV.UK).

First-of-anything returns deserve extra care for three practical reasons. First, the boxes themselves are new: no taxpayer, no software house and no HMRC officer has a prior year's FIG return to compare against, so errors will not be caught by habit. Second, the quantification rule has real teeth. HMRC's manual states there is no de minimis or automatic application of the relief, that a claim for year one will not automatically carry into years two, three or four, and that a claim which is not quantified at all is invalid (RFIG42100, HMRC). Third, a new relief with no filing history is exactly the sort of thing tax authorities look at closely in its early years, because the mistakes cluster there. Our guide to FIG regime penalties covers what an invalid or careless claim can cost; this one is about not getting there.

None of this is a reason to avoid claiming. For someone with significant foreign income in their first four UK years, the relief is generous and entirely legitimate. It is a reason to prepare the claim properly, with the numbers reconciled to statements and the eligibility checked year by year, rather than assembling it in the last week of January. If you want the regime itself explained first, start with our full guide to the 4-year FIG regime.

The deadlines that frame the season

Every date below is fixed by statute or HMRC practice and verified against GOV.UK. The online filing and payment deadlines fall on 31 January 2027 for the tax year that ended 5 April 2026 (GOV.UK).

DateWhat happensWho it affects
5 October 2026Deadline to tell HMRC you need to complete a 2025/26 return, by registering for Self AssessmentAnyone not already registered, which includes most 2025/26 arrivers
31 October 2026Paper returns must reach HMRC by 11:59pmAnyone filing the SA109 on paper rather than through software or an agent
30 December 2026Online filing deadline if you want an underpayment under £3,000 collected through your PAYE tax codeEmployees and pension recipients with smaller balances
31 January 2027Online returns due by 11:59pm; 2025/26 tax due; first 2026/27 payment on account due where applicableEveryone filing online, which for FIG claimants means commercial software or an agent
31 July 2027Second 2026/27 payment on account dueAnyone within the payments on account rules
Key dates for the 2025/26 FIG filing season.

The trap inside this table is the filing route. HMRC's free online Self Assessment service cannot handle the SA109 residence pages: GOV.UK's own guidance says you cannot use HMRC's online services to report as a non-resident, and points instead to paper by 31 October, commercial software that supports the SA109, or a tax professional (GOV.UK). Every FIG claim lives on the SA109, so this applies to every FIG claimant. Discover it in mid January and your options have narrowed to buying and learning software in a fortnight or finding an agent with capacity in the busiest week of the tax year. Our guide to why the SA109 cannot be filed on HMRC's website covers the options in detail.

Newly arrived? Registration and the UTR queue come first

If you became UK resident in 2025/26 and have never filed a UK return, you cannot file anything until you are registered for Self Assessment and hold a Unique Taxpayer Reference. GOV.UK is clear on the deadline: you must tell HMRC by 5 October 2026 if you need to complete a return for the previous tax year, and registering late can mean a penalty (GOV.UK).

GOV.UK does not promise a turnaround time for the UTR; it directs you to a separate tool to check when you can expect a reply. In our experience the wait is measured in weeks, and it lengthens as the season peaks, because everyone who left registration late is in the same queue. Newly arrived clients also often need to set up Government Gateway credentials and verify their identity, which adds its own steps. The safe reading of all this is simple: registration is an August or September job. A FIG claimant who starts the process in December is gambling their first claim on HMRC's post room.

One more first-season point for arrivers: the claim year matters. The regime is available for your first four tax years of UK residence, after at least 10 consecutive non-resident tax years, and if you first became resident before 6 April 2025 you can only claim for the years from 2025/26 that remain in your window (GOV.UK). Check where your window falls with our deadlines by arrival year guide before anything is filed.

Split-year arrivals: the claim still works, the clock still runs

Most people who moved to the UK during 2025/26 will claim split-year treatment, dividing the year into an overseas part and a UK part. Two questions follow for FIG purposes, and HMRC's manual answers both.

First, does a split year count as a full year of the four-year window? Yes. The manual states that any year in which split year treatment applies is a full year of UK residence for the residence criteria, because the individual is resident under the Statutory Residence Test for the whole tax year (RFIG44000, HMRC). Arrive in February 2026 and 2025/26 still burned the first of your four years.

Second, can you claim FIG relief in a split year? Also yes. The same page confirms that a qualifying new resident can claim under the FIG regime in a split year, including in respect of taxable income and gains arising in the overseas part of the year where they qualify for relief. In practice most overseas-part foreign income falls outside UK tax under the split-year rules anyway, but amounts that remain taxable can be swept into the claim. For a 2025/26 arriver this means the first return carries three interlocking pieces: the SA109 split-year claim, the residence disclosures, and the quantified FIG claim, all of which have to tell one consistent story. This is precisely where first-season mistakes concentrate.

Payments on account: why the first January bill can be 150%

The most common first-year shock has nothing to do with the FIG rules at all. Payments on account are advance payments towards your next tax bill. You must make them unless your last Self Assessment bill was under £1,000, or more than 80% of your tax was collected at source, for example through PAYE. Each payment is half of your previous year's bill, due by midnight on 31 January and 31 July (GOV.UK).

For a first-time filer there is no previous year, so nothing was paid in advance. That means 31 January 2027 collects the entire 2025/26 liability at once, and, if your bill is over £1,000 and mostly not collected at source, the first 2026/27 payment on account lands the same day: half the 2025/26 bill again. A £20,000 liability becomes a £30,000 January payment, with another £10,000 following on 31 July 2027.

FIG claimants are squarely in scope. Claiming relieves the foreign income and gains you quantify, but it also costs you the £12,570 Personal Allowance and the £3,000 CGT annual exempt amount for the year (HS266, GOV.UK), so UK salary, UK rental profits or UK gains are taxed from the first pound. Plenty of first FIG returns therefore produce a meaningful bill even with every foreign source relieved. Knowing the number in October, with three months to arrange the cash, is a very different experience from learning it on 29 January.

What to gather now

A FIG claim is quantified source by source, so the return is only as good as the paperwork behind it. Everything below relates to the year ended 5 April 2026, and most of it comes from institutions that take weeks to respond, which is why August is the month to ask. Our record-keeping guide covers the full system; this is the season's shopping list.

  • Your residence history for the 10 tax years before arrival, with days in and out of the UK, to evidence the 10 consecutive non-resident years the claim depends on.
  • Travel records for 2025/26 itself: arrival date, UK day counts and the facts supporting your split-year case if you arrived mid-year.
  • Year-end statements for every foreign bank and brokerage account showing interest and dividends credited between 6 April 2025 and 5 April 2026, in the source currency.
  • Completion statements and cost history for any foreign assets sold in the year, so each gain can be computed and reported individually on the SA108.
  • Foreign rental accounts, foreign trade or business profits, and any foreign pension or distribution paperwork for the year.
  • UK-side documents: P60 or P45, UK bank interest, UK dividend vouchers and UK rental figures, since these stay fully taxable with no Personal Allowance in a claim year.
  • For former remittance-basis users, a schedule of pre-6 April 2025 foreign income and gains, because the Temporary Repatriation Facility's 12% window closes on 5 April 2027 and designations deserve the same season's attention.

Your month-by-month timeline to 31 January 2027

Worked backwards from the deadline, the season looks like this. The dates assume you are filing online through software or an agent, which is how almost all FIG returns will go.

MonthWhat to doWhy then
August 2026Confirm eligibility: 10 prior non-resident years and your window position. Register for Self Assessment if you have never filed. Request year-end statements from every foreign institutionRegistration and overseas paperwork both run on lead times you do not control; starting now absorbs them
September 2026Choose the filing route: agent or SA109-capable commercial software. Chase missing statements. Instruct an adviser if you want one, while capacity existsThe 5 October registration deadline is close, and advisers fill their winter diaries early
October 2026Registration deadline 5 October. Paper deadline 31 October if that is your route. Complete the claim-or-not arithmetic for the yearThe paper option dies this month; the claim decision drives everything drafted afterwards
November 2026Draft the return: split-year pages, quantified FIG claim, SA106 and SA108 schedules reconciled to statementsDrafting with complete papers takes days; drafting while chasing papers takes months
December 2026Review and file. 30 December deadline if you want a sub-£3,000 balance collected through your tax codeFiling before the holidays leaves January free for payment, not panic
January 2027Pay the 2025/26 balance and any first payment on account by 31 JanuaryThe money deadline is the real deadline; a filed return with an unpaid bill still accrues interest
Month-by-month preparation timeline for the 2025/26 FIG filing season.

The pattern to notice: every substantive decision sits in August to October. By November the work is assembly, and by January the only job left should be payment. People who invert the timeline, deciding in January what to claim, discover the software problem, the UTR queue and the 150% bill all in the same week.

How Horizon handles the first FIG season

FIG returns are exactly the returns Horizon UK Tax Solutions specialises in. The practice is founder-led by a Chartered Tax Adviser with over 10 years' experience, including 7 at a Big Four firm, and cross-border Self Assessment is the core of what we do: eligibility review against the 10-year rule, the claim-or-not arithmetic, split-year analysis, the quantified source-by-source schedules, and filing through professional software that handles the SA109 properly. You will not be our first FIG return of the season.

Fees are fixed and agreed upfront, so the price you are quoted is the price you pay: personal tax returns from £350, non-resident and expat returns from £550, and complex returns from £750. If you are weighing up whether to handle the first season yourself, our guide to whether you need an accountant for the FIG regime sets out the honest dividing line.

The practical step is simple: book a free 30-minute clarity call now, while the timeline above still has slack in it. We will tell you whether the claim makes sense for your numbers, what your January 2027 payment is likely to look like, and exactly what to gather. You can read more about the service on our non-dom and residency page. Instruct in August and January is quiet; instruct in January and you are queueing with everyone else who waited.

Need this applied to your own situation?

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Frequently asked

Fig regime filing deadline 2025/26: your questions answered

Jordan Onraet-Wells, Founder & Chartered Tax Adviser (CTA)

Written and reviewed by

Jordan Onraet-Wells

Founder & Chartered Tax Adviser (CTA)

Horizon UK Tax Solutions is led by Jordan, a Chartered Tax Adviser (CTA) and accountant with over 10 years of experience, including 7 years at a Big Four professional services firm. Jordan specialises in cross-border taxation, expat tax planning, and helping businesses navigate multi-country compliance.

This guide is general information for the 2026/27 UK tax year, not personal tax advice; speak to a Chartered Tax Adviser about your own position.

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