FIG Regime Record Keeping: The Evidence HMRC Expects Behind Every Claim

The FIG regime is claimed annually on the SA109 residence pages, box 28 for foreign income and box 29 for foreign gains, and helpsheet HS266 requires every relieved amount to be reported separately: you must claim for each amount of foreign income, from each source, on the SA106 foreign pages, and each qualifying foreign gain on the SA108 capital gains pages (HS266, GOV.UK). The amounts must be calculated for the tax year, under the normal tax calculation rules for each type of income.

HMRC's manual is explicit about what that means in practice. The amount of relief being claimed must be quantified in the return, income and gains must be claimed on a source-by-source basis, and not quantifying a claim at all invalidates it. If you quantify a claim at a lower figure than you were entitled to, only the declared amount is relieved (RFIG42100, HMRC). Every one of those numbers is a number you must be able to defend, which is why the record-keeping described in this guide is not optional housekeeping. It is the substance of the claim. Our SA109 walkthrough covers the boxes themselves; this guide covers the file that sits behind them.

Eligibility requires at least 10 consecutive tax years of non-UK residence immediately before you became UK resident, with each of those years judged under the Statutory Residence Test (GOV.UK). HMRC does not certify your residence history in advance. If the claim is checked, you prove those 10 years yourself, and a single UK-resident year inside the run breaks the sequence and the claim with it.

The strongest file works year by year, not by general impression. For each of the 10 years you want evidence of your UK day count and your ties. Passport stamps, airline booking confirmations and frequent flyer statements evidence days in and out of the UK. Old Self Assessment returns with SA109 pages showing non-residence are powerful, as is the absence of any UK filing obligation in years when you had no UK income. A P85 is useful too: it is the form that told HMRC you had left the UK and whether you expected to work full time abroad, although you did not need one if you filed a Self Assessment return for the year you left (P85 guidance, GOV.UK). Round the picture out with foreign tax returns or residence certificates, overseas employment contracts, foreign payslips, tenancy agreements or property purchase records abroad, and utility bills at your overseas home.

One caution: a P85 or even a foreign residence certificate does not decide UK residence. Only the Statutory Residence Test does, applied to your actual days and ties for each year. The documents are evidence for that test, not a substitute for it. Where a year is marginal, perhaps a year with heavy UK visits or an accommodation tie, work the SRT properly for that year and keep the working. Returning British expats should take particular care here, because their earlier UK life makes ties easier to trip; our guide to the FIG regime for returning British expats covers the pattern.

Your first year of UK residence fixes the four-year window, and the window is fixed even if it started before the regime existed on 6 April 2025. A split year of arrival still burns a full year of the window, so establishing exactly which tax year you became resident, and when in that year you arrived, is worth real money. Our deadlines by arrival year guide maps each arrival year to its claimable years.

Keep the documents that pin the date down: the visa or status grant, flight records for the arrival itself, the tenancy agreement or completion statement for your UK home, your employment contract start date or first UK payslip, school enrolment for children, and registration with a GP. The same records that prove your arrival date also support any split-year case and establish which foreign income arose before UK residence began, which matters because income arising in the overseas part of a split year is outside UK tax altogether and should not be burned as part of a FIG claim.

Because the claim is source by source, the working papers should be too. For foreign bank interest, that means a schedule per account: bank, country, account reference, each interest credit with its date, the amount in local currency and the sterling conversion. For dividends, a schedule per holding: company, number of shares, each payment date, gross amount and any foreign withholding tax, converted to sterling. Broker and platform annual tax reports help, but check they cover the UK tax year to 5 April rather than a calendar year, because a calendar-year report always needs re-cutting before it can support a UK return.

Overseas rental profits need proper income and expense records for the property business: rent received, agent statements, invoices for repairs and other allowable costs, loan statements, and a profit computation for the tax year under UK rules. Foreign rules for depreciation and deductions differ from UK ones, so the foreign tax return figure is rarely the UK figure; keep the reconciliation. Fund investments deserve special care: keep the fund's own statements, including any amounts the fund reports as taxable income to investors even where nothing was paid out, because those amounts are income for UK purposes and belong in the claim schedule with everything else.

For capital gains, HMRC's rule is strict and frequently got wrong. The gain must be computed in sterling: an amount of foreign currency is converted into its sterling value at the time it is incurred or received, so acquisition cost converts at the exchange rate in force at the date of acquisition and proceeds convert at the rate in force at the date of disposal. HMRC will not accept a computation done in the foreign currency with only the final gain converted to sterling (CG78310, HMRC). The two methods can produce very different answers, because the sterling method taxes currency movement as well as asset growth. Keep the full computation per disposal: acquisition date and cost, disposal date and proceeds, incidental costs, and the rate used at each date.

HMRC does not prescribe one official rate. Its Business Income Manual confirms that rates complying with generally accepted accounting practice are acceptable, and names London closing rates, bank-quoted exchange rates and HMRC's own published monthly average rates as acceptable sources. HMRC will only query the rate used if, exceptionally, it diverges markedly from rates obtained from reputable sources (BIM39515, HMRC). For gains, the requirement from the Capital Gains Manual is a rate in force at the transaction date, applied through a reasonable and consistent method (CG78310, HMRC).

The practical discipline is simple: choose one reputable source, document the choice, and apply it consistently across the whole return and from year to year. For income that arises steadily, such as monthly interest or rent, a published monthly rate applied month by month is defensible and easy to evidence. For one-off events, a large dividend, a disposal, a fund distribution, use the rate for the actual date. Whatever you choose, print or save the rate tables you used and file them with the schedules. A claim where every conversion can be traced to a saved rate table is a claim an HMRC officer can agree quickly.

The statutory minimums are shorter than most people expect, and far shorter than a FIG file deserves. If you are not in business, GOV.UK says to keep the records for a return for at least 22 months after the end of the tax year it covers, so records for a 2025/26 return filed by 31 January 2027 should be kept until at least the end of January 2028. File late and the period becomes at least 15 months after you sent the return (GOV.UK). Where the return includes business income, the rule for the self-employed is 5 years after the 31 January submission deadline (GOV.UK), and anyone with rental profits should work to that same 5-year standard.

For a FIG file, treat the statutory minimums as a floor, not a target. The 10-year residence history supports every year of the four-year window, so the same evidence may need to be produced for returns filed years apart, and offshore matters generally attract longer HMRC attention than domestic ones. Our advice to clients is blunt: keep the entire FIG file, residence evidence included, for the whole window and for several years beyond your final claim year. Storage is free; reconstruction is not. If records are genuinely lost, GOV.UK expects you to try to recreate the figures and to tell HMRC where amounts are estimated or provisional, which is a far weaker position in an enquiry than a complete file.

If HMRC opens a compliance check into a FIG claim, it does not have to rely on polite requests. An information notice is a legal document that requires a person to provide information and produce documents, and HMRC can ask for any information or documents it believes are relevant to your tax position where it is reasonable to ask for them (CC/FS2, GOV.UK). For a FIG claim, that reasonably reaches foreign bank statements, broker reports, residence evidence for the 10-year run, and the computations behind every relieved figure.

The penalty structure makes non-compliance expensive: £300 for failing to comply by the deadline, daily penalties of up to £60 for continued failure, and up to £3,000 for each careless or deliberate inaccuracy in the information provided. There are limits, and some safeguards: HMRC cannot demand documents you do not have or cannot reasonably obtain, or communications covered by legal privilege, and most notices carry appeal rights. But you cannot appeal against a requirement to produce statutory records, the records the law already obliged you to keep, or against a notice approved by the independent tribunal (CC/FS2, GOV.UK). The practical conclusion runs one way: a claim built on records you can hand over within the deadline is cheap to defend, and a claim built on memory is not. Our guide to FIG penalties when it goes wrong covers what happens after that point.

The table below is the checklist we build for clients before any FIG return is prepared. One row per source type, three questions per row: what evidences the amount, what converts it to sterling, and what proves it belongs in the claimed year.

If a row on that table makes you wince, that is the row to fix now, while the 2025/26 filing season is open and there is still time to gather statements calmly. The first filing season guide sets out the timetable to 31 January 2027.

FIG returns are exactly the returns we specialise in. Horizon UK Tax Solutions is founder-led by a Chartered Tax Adviser with over 10 years' experience, including 7 at a Big Four firm, and every FIG return we file is built the Big Four way: a working paper file behind every number. That means a year-by-year residence analysis for the 10-year run, an arrival-year and split-year position, per-source schedules for each account, holding and property, sterling conversions traced to saved rate tables, and gains computations that follow HMRC's sterling method line by line. If HMRC ever asks, the answer is a file, not a scramble.

We do this on fixed fees agreed upfront, so the record-heavy nature of a FIG return never becomes an hourly-billing problem. Personal tax returns start from £350, non-resident and expat returns from £550, and complex returns from £750. If you are weighing up whether your first FIG year is one to handle alone, our guide on whether you need an accountant for the FIG regime gives an honest answer, and our non-dom and residency service page sets out how the engagement works.

The simplest next step is a free 30-minute clarity call. Bring whatever records you have, however incomplete; we will tell you what is missing, what it will take to fill the gaps, and quote a fixed fee for the return before any work starts.