The FIG Regime for Investors and High Earners: Four Years to Get the Big Numbers Right

The FIG regime relieves qualifying foreign income and qualifying foreign gains that arise on or after 6 April 2025 in a year for which you are a qualifying new resident and make a claim. HMRC's manual lists the income categories, and for investors the list is generous: "dividends from non-UK resident companies", "interest, such as interest paid on a foreign bank account", "profits of an overseas property business", royalties and other income from intellectual property, profits from deeply discounted securities, purchased life annuity payments, foreign pension income and the profits of a trade carried on wholly outside the UK, including a partner's share of such a trade (RFIG45100, HMRC).

On the gains side, the test is asset location rather than income type: a gain qualifies where it accrues on "the disposal of an asset situated outside the UK" and "the asset does not derive at least 75% of its value from UK land" (RFIG45500, HMRC). That second limb matters for investors: shares in a property-rich company can fail the test even when the company itself is foreign. The regime also reaches gains attributed to UK residents from non-UK close companies and from non-resident settlements, which is relevant if your holdings sit inside offshore structures.

What never qualifies: UK source income of every kind, so UK dividends, UK interest and UK rental profits are taxed as normal, and so are gains on UK situated assets. Foreign employment earnings are excluded too: "Relevant foreign earnings and foreign specific employment income are not qualifying foreign income", and salary for overseas duties needs the separate Overseas Workday Relief election instead, which has its own new rules (HS266, GOV.UK). A narrow class of disqualified income, including certain settlement-related income and some pension types, is also carved out.

Most internationally mobile investors hold offshore funds, and the UK taxes them along a line that has nothing to do with where the fund is based: whether the fund has HMRC reporting status. Dispose of a reporting fund and "you will be subject to Capital Gains Tax on any gain you realise". Dispose of a non-reporting fund and "any gain you realise will normally be treated as an 'offshore income gain'", taxed to Income Tax rather than Capital Gains Tax (HS265, GOV.UK). Reporting funds also produce excess reported income: investors "are taxed on their full share of reportable income, even if it has not been distributed".

For FIG purposes the good news is that both routes can be relieved, but they sit on different sides of the claim. Offshore income gains appear in HMRC's list of qualifying foreign income at RFIG45100, so a non-reporting fund disposal goes into the foreign income claim, not the gains claim. A reporting fund disposal produces a chargeable gain, which qualifies on the gains side where the fund interest is an asset situated outside the UK and clears the UK land test at RFIG45500.

This classification is exactly where large FIG returns go wrong. Because the claim is made source by source, a portfolio of thirty fund lines needs each line classified as reporting or non-reporting, each disposal computed under the right rules, and each amount placed in the right box. Getting a non-reporting fund into the gains claim, or missing excess reported income entirely, produces a wrong return with six-figure numbers on it. Our guides on FIG record keeping and what happens when a FIG return is wrong cover the fallout in detail.

Under the old remittance basis, sheltering foreign income meant exiling it: the moment relieved money touched the UK it became taxable, so non-doms ran segregated account structures and kept capital offshore for decades. The FIG regime abolishes that trade-off completely. Income and gains relieved under a valid claim can be transferred to a UK account, spent on a UK house or invested in UK assets with no tax charge, in the year they arise or any later year (HS266, GOV.UK).

For wealthy arrivers this changes behaviour, not just tax bills. A four-year window in which foreign dividends and realised gains can be received tax free and moved onshore freely is, in effect, an invitation to fund your UK life, and your UK asset base, out of relieved money while the window is open. There is no remittance planning, no mixed fund analysis for the new money, and no charge when it lands. Our comparison of FIG and the remittance basis sets out how different the two systems really are.

One caution for former remittance basis users: the freedom applies to income and gains arising on or after 6 April 2025 that you relieve under a FIG claim. Older money that accrued under the remittance basis is still taxable if remitted, unless designated under the Temporary Repatriation Facility, covered below.

The regime is available for a maximum of four consecutive tax years from your first year of UK residence, after at least 10 consecutive non-resident years, and unused years do not roll forward (GOV.UK). For an investor, that turns the window into a scheduling problem: relief only touches income and gains that actually arise in a claimed year.

The planning follows directly. A foreign shareholding you intend to sell anyway is worth selling inside the window rather than in year five, when the same gain is taxed at 24%. A private company that can pay dividends has four years in which those dividends reach you free of UK tax, against dividend rates of up to 39.35% afterwards. Deferring income out of habit, rolling up gains in a fund, holding dividends back in a company, is precisely the wrong instinct here: anything that arises after your final claimed year is fully taxable, and anything that arose before 6 April 2025 was never eligible.

The final year varies by arrival date, and arrivers before 2025/26 have shortened windows because the regime cannot be claimed for earlier years. Check your own dates against our deadline table by arrival year, and remember that the first FIG filing season is running now: 2025/26 returns are due by 31 January 2027, as our first filing season guide explains.

Claiming FIG for a year costs your tax-free allowances: the Personal Allowance, the Capital Gains Tax annual exempt amount and certain other allowances go in full, even if you claim on only one source (HS266, GOV.UK). For modest foreign income that trade-off can make a claim uneconomic. At investor-scale numbers it almost never does, for a simple reason: the Personal Allowance is already tapered away by £1 for every £2 of income above £100,000 and reaches nil at £125,140 (GOV.UK). A high earner gives up an allowance they no longer have.

Take a qualifying new resident in 2026/27 with £200,000 of dividends from non-UK companies, a £300,000 gain on foreign shares, and no other income. Without a claim, the dividends are taxed at the 2026/27 dividend rates of 10.75%, 35.75% and 39.35% with a £500 dividend allowance (GOV.UK): £37,200 in the basic band at 10.75% is £3,999, the £87,440 higher band slice at 35.75% is £31,260, and the £74,860 above £125,140 at 39.35% is £29,457, a total of £64,716. The gain, after the £3,000 annual exempt amount, is taxed at 24% (GOV.UK): £297,000 at 24% is £71,280. Total UK tax: £135,996.

With a FIG claim, both amounts are relieved in full and the UK tax is nil. The cost of the claim is the loss of a Personal Allowance already worth nothing at this income level, plus the £3,000 annual exempt amount, worth £720 at 24%. In other words, the trade-off that genuinely bites at £5,000 of foreign interest costs a six-figure claimant about £720 against a saving of £135,996. The arithmetic still deserves a check every year, because the claim is annual and optional, but at this scale it points one way.

Many investors now in their FIG window, and many who no longer qualify, have older foreign income and gains that accrued while they used the remittance basis. That money is still taxable if brought to the UK. The Temporary Repatriation Facility lets former remittance basis users designate this pre-6 April 2025 qualifying overseas capital and pay a flat charge instead: 12% of the amount designated in a 2025/26 or 2026/27 return, rising to 15% for 2027/28, after which the facility ends (RDRM73400, HMRC).

Two features make the TRF genuinely useful alongside a FIG claim. First, designation is what triggers the charge, not remittance: HMRC confirms individuals "do not have to remit the designated amount during the TRF period" to lock in the low rate, so you can designate now at 12% and move the money later (RDRM71000, HMRC). Second, once designated and taxed, the capital comes onshore with no further UK tax, which pairs naturally with the FIG window's free movement of new money. The practical deadline is 5 April 2027 for the 12% rate; our full TRF guide covers designation mechanics and mixed funds.

None of the above happens automatically. The claim is made on your Self Assessment return, and HMRC's manual is explicit that "income and gains to be relieved must be claimed on a source-by-source basis", that "the amount of relief being claimed must be quantified in the relevant tax return", and that "not quantifying a claim at all does invalidate the claim" (RFIG42100, HMRC). On the forms, that means boxes 28 and 29 on the SA109 plus full reporting of every relieved source on the SA106 foreign pages, SA108 gains pages or the trading and partnership pages, as our SA109 walkthrough shows. An invalid claim does not mean a lost discount; it means undeclared foreign income of a UK resident.

And undeclared foreign income sits in the harshest corner of the penalty rules. Inaccuracies involving offshore matters carry maximum penalties of 100%, 150% or 200% of the tax depending on the territory category of the jurisdiction involved, and where the underlying penalties are serious enough an additional asset-based penalty of up to 10% of the asset's value can apply (CC/FS17, GOV.UK). On a return carrying £500,000 of relieved income and gains, the gap between a correct claim and a careless one is not measured in hundreds of pounds. The records behind each figure, fund statements, dividend vouchers, completion statements, residence evidence for the 10-year test, need to exist before the return is filed, not after HMRC asks; our record keeping guide lists what to hold.

FIG returns with substantial investment income 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 the work is the full job: confirming your qualifying new resident status against the 10-year and 4-year tests, classifying every fund line and income source, running the claim-versus-no-claim arithmetic at your numbers, quantifying the claim source by source across the SA109, SA106 and SA108, and coordinating a TRF designation where old remittance-era money is in play.

Fees are fixed and agreed upfront: personal tax returns from £350, non-resident and expat returns from £550, and complex returns, which is where most investor FIG claims sit, from £750. If you are weighing up whether to handle it yourself, our guide on whether you need an accountant for the FIG regime gives an honest split of who can and who should not.

The first FIG filing season is open now, with 2025/26 returns due by 31 January 2027, and the 12% TRF rate expires on 5 April 2027. If your window is running, book a free 30-minute clarity call or see our non-dom and residency service. Twenty minutes on your sources and dates is usually enough to say what the claim is worth and what it will cost to do properly.