Moving to the UK from the Gulf: Tax Planning for High-Net-Worth Arrivals

Once you are UK tax resident, you are in principle taxable in the UK on your worldwide income and gains, wherever they arise and whether or not you bring the money into the country. This is the headline shift for anyone arriving from a Gulf state where personal income tax is nil. Salary, investment income, rental profits, business distributions and capital gains from anywhere in the world can fall within the UK net.

The old remittance basis, which let non-doms keep foreign income and gains outside UK tax as long as the money stayed offshore, was abolished from 6 April 2025. In its place, the 4-year FIG regime offers eligible new arrivals a defined window of full relief on foreign income and gains. If you do not qualify for FIG, or the four years have run out, you are taxed on the arising basis on your worldwide income and gains like any other UK resident. Understanding which side of that line you fall on is the starting point for all planning.

Your residence status is decided by the Statutory Residence Test (SRT), not by your passport, your visa or your intentions. The SRT is applied for each tax year (6 April to 5 April) and works through three stages in order.

• The automatic overseas tests: if you meet any of these, you are non-resident for the year. The most relevant for arrivals is spending fewer than 16 days in the UK if you were resident in one or more of the previous three tax years, or fewer than 46 days if you were resident in none of them.
• The automatic UK tests: if you meet any of these, you are UK resident. Spending 183 or more days in the UK in a tax year makes you resident automatically, as can having your only or main home in the UK or working full-time here.
• The sufficient ties test: if neither set of automatic tests is met, your residence depends on combining the number of days you spend in the UK with your UK ties (family, accommodation, work, 90-day and, for leavers, country ties).

For someone moving from the Gulf, the practical questions are how many days you will spend in the UK, when in the tax year you arrive, and which ties you will have. Careful day-counting from the outset is essential, and split-year treatment may apply in the year you arrive so that only the UK part of the year is taxed on the arising basis. Model your position before you commit to travel dates.

The Foreign Income and Gains (FIG) regime is the replacement for the non-dom remittance basis and is the centrepiece of planning for new arrivals. If you qualify, you can claim 100% relief on your qualifying foreign income and on your foreign gains for up to your first four tax years of UK residence. You pay no UK tax on the relieved amounts, and, unlike under the old rules, you can bring that money into the UK freely with no further tax charge on remittance.

Three features matter for Gulf HNWs. First, only foreign income and gains arising on or after 6 April 2025 can qualify, so a former remittance-basis user cannot use FIG to shelter pre-6 April 2025 income and gains. Second, the relief is claim-based: you must make a claim on your Self Assessment return for each year and for each category (foreign income, foreign gains, or both) you want covered. You can claim in some of the four years and not others, but unused years are lost, there is no rollover. Third, claiming has a cost. For any year you claim, you give up your tax-free allowances for income tax and capital gains tax, meaning the income tax personal allowance and the CGT annual exempt amount, along with the marriage and blind person's allowances where relevant.

Because of that trade-off, a FIG claim is generally worthwhile only where the foreign income and gains being relieved comfortably outweigh the value of the allowances you surrender. For an arrival with a large offshore investment portfolio, Gulf business interests or a foreign salary, the maths is usually overwhelmingly in favour of claiming. For someone with modest foreign income, it may not be. Each year should be assessed on its own facts, and a FIG eligibility check is a sensible first step.

The gateway to the FIG regime is a strict residence condition. You are a qualifying new resident only if you are within your first four years of UK residence following at least 10 consecutive tax years of non-UK residence. Crucially, this is about your residence history under the SRT, not your domicile, nationality or where you were born. A British expat returning after a decade or more in the Gulf qualifies on exactly the same footing as a first-time arrival, provided the 10-year clock is clean.

That clock is where returning Brits most often come unstuck. If you spent even a single tax year as UK resident within the preceding 10 years, for example on a short assignment back home, you break the 10-consecutive-year requirement and the FIG regime is not available. This is why an honest, evidenced SRT review of every one of the last 10 tax years is the first thing to do. Do not assume you qualify because you have lived abroad for years, prove it, because HMRC will expect you to.

The most valuable planning happens while you are still non-resident, because once you are UK resident your options narrow sharply. Consider the following before you become UK tax resident.

• Realise gains while non-resident. Gains you crystallise before you become UK resident are generally outside UK CGT altogether, subject to the temporary non-residence anti-avoidance rules if you have recently been UK resident and return within roughly five years. Selling and repurchasing appreciated assets while still in the Gulf can reset your base cost cleanly.
• Mind UK property separately. If you sell UK residential property while non-resident, non-resident CGT still applies and the disposal must be reported and any tax paid within 60 days of completion, with residential gains taxed at 18% or 24% depending on your income band. This is a distinct obligation from the arising-basis rules above.
• Rebasing and record-keeping. Establish and document the market value of your assets as at your arrival date, so that only post-arrival growth is ever within UK scope. Contemporaneous valuations are far stronger than reconstructions years later.
• Segregate clean capital. Keep capital that you accumulated before arriving in a separate, clearly identified account, distinct from post-arrival income and gains. Clean capital can be brought into the UK without a tax charge, but only if you can show it is clean, so mixed accounts are the enemy.
• Document your source of funds. Gulf banking and UK anti-money-laundering checks both demand a clear paper trail. Keep evidence of how wealth was earned and where it has sat. This protects you at the point of remittance and when banks or advisers ask questions.
• Time the arrival tax year. Because the SRT operates by tax year and split-year treatment can apply, when you arrive relative to 6 April can change your exposure materially. Arriving early in a tax year versus late in the previous one is a decision to model, not to leave to chance.

None of this is available in the same way once you are resident. This is the single biggest reason to take advice months, not weeks, ahead of a move.

One of the practical advantages of the new regime is that FIG-relieved money can be brought into the UK without a further tax charge. That removes the old trap where non-doms had to keep foreign income and gains offshore forever to avoid a remittance charge. If you claim FIG on foreign income or gains, you can use that money to buy a UK home, fund living costs or invest here, with no remittance tax.

The picture is different for wealth accumulated before 6 April 2025 if you previously used the remittance basis. Those historic foreign income and gains still carry latent remittance exposure if brought to the UK, which is exactly what the Temporary Repatriation Facility is designed to unlock. The TRF lets former remittance-basis users designate pre-6 April 2025 foreign income and gains and pay a flat charge of 12% for the 2025/26 and 2026/27 tax years, rising to 15% for 2027/28. Once capital has been designated, it can be remitted freely, and designation does not itself require you to remit the money during the window. For anyone with a legacy offshore pot and historic remittance-basis use, the TRF is a genuinely favourable, and strictly time-limited, opportunity that should be assessed now.

Inheritance tax (IHT) was also put on a residence basis from 6 April 2025. Domicile no longer drives your IHT exposure. Instead, your worldwide estate is broadly within the scope of UK IHT once you have been UK resident for at least 10 of the previous 20 tax years, at which point you become a long-term UK resident for IHT.

For a new arrival, this is reassuring in the short term: for your first years in the UK, only your UK situated assets are typically in scope, and your Gulf and other non-UK assets sit outside UK IHT until the 10-year threshold is crossed. Once you become a long-term UK resident, the scope does not switch off the moment you leave. A tail applies: you remain within UK IHT scope for between 3 and 10 years after departure, scaling with how long you were resident. For example, someone resident for 15 of the previous 20 tax years on leaving would remain in scope for 5 years, and someone resident for 17 of 20 would remain in scope for 7 years, up to a maximum of 10. Anyone planning to be in the UK for the medium to long term should factor this into estate and structuring decisions early, well before the 10-year point arrives.

Companies and trusts still have a place in cross-border planning, but the residence-based reforms have changed the calculus. Trust protections that were valuable under the old non-dom rules have been largely dismantled, and offshore structures can now expose settlors and beneficiaries to UK income tax, CGT and IHT in ways they did not before. A structure that made sense in the Gulf, or under the pre-2025 UK regime, may now create more problems than it solves.

The right approach is to review any existing offshore company or trust against the current rules before you become UK resident, and to be cautious about creating new structures without a clear, tested UK tax rationale. Poorly matched structures are one of the more common and expensive mistakes we see among incoming HNWs. This is precisely the kind of ongoing oversight our Global Compliance Manager service is built to provide: a single point of accountability keeping your FIG claims, TRF designations, residence position and structures aligned across every jurisdiction, year after year.