Britain's framework for people who arrive with foreign money now runs on years of residence, not on where they are domiciled. New arrivals get four tax years of relief on foreign income and gains, and only after a decade of clean non-residence abroad. Inheritance tax counts differently: ten years of UK residence inside the previous twenty, then a tail that follows you out.
It is in its second tax year: the earliest arrivals are running out of relief and the transitional windows are closing.
Three parts, three different clocks
The remittance basis — which let UK residents domiciled elsewhere pay UK tax only on what they brought in — ended on 6 April 2025. Section 40 of the Finance Act 2025, whose Royal Assent was on 20 March 2025, makes it "not available for tax year 2025-26, or for subsequent tax years". Earlier years keep the old rules.
Three things replaced it: four years of relief on foreign income and gains for new arrivals (sections 37 to 39); a residence test replacing domicile for inheritance tax (section 44), in force from 6 April 2025; and transitional facilities with closing dates.
The Finance Act 2026, Royal Assent 18 March 2026, amended rather than replaced this, rewriting parts of the temporary repatriation facility in Schedule 3 and capping inheritance tax charges on property excluded before 30 October 2024.
The decade you have to prove
The window is not open to everyone who arrives. The test for a "qualifying new resident", in new section 845B of the Income Tax (Trading and Other Income) Act 2005, requires that the individual was not UK resident for each of the 10 tax years before the first qualifying year — ten consecutive years of non-residence, in HMRC's phrasing.
That reshapes the decision for the returning family: a couple who left in 2018 and return in 2026 have eight years away, and eight is not ten. They arrive with no relief at all, taxed on the arising basis from day one.
Against the day-count machinery, that is a sharp edge: a family that kept the London house and the school place can be resident on well short of 183 days, and one resident tax year anywhere in the ten before arrival disqualifies the whole window. Tax residence is a story you tell in days set out that arithmetic; what changed is what the count buys.
The window is four consecutive years beginning when UK residence started, not when you filed, and unused years cannot be rolled over. Nationality, domicile and any past remittance basis claim are irrelevant.
Inheritance tax counts differently, and longer
Inheritance tax reaches further back. You become a long-term UK resident, and so exposed to UK inheritance tax on worldwide assets, once you have been UK resident for at least 10 of the previous 20 tax years — counted over the twenty ending with your last year of UK residence.
Leaving does not end it. The tail runs three years if you were resident for 13 of those years or fewer, then rises by a year for each additional year, to a maximum of 10. HMRC's published examples run from three years, for ten to thirteen years of residence, to five years, for fifteen. Only after 10 consecutive years of non-residence is the ten-out-of-twenty test reset.
There is a carve-out for people who left before the framework began, and it turns on one date. If on 30 October 2024 you were neither UK domiciled nor deemed domiciled, you were non-resident for 2025-26 and do not return, you are not a long-term UK resident; those deemed domiciled on that date keep the status through three years of non-residence, then lose it.
The deadlines that are still open
The temporary repatriation facility is the mechanism for old money: pre-6 April 2025 foreign income and gains never remitted to the UK. Designate them, pay the charge, and they can be brought in clean. It runs for three tax years — 2025-26, 2026-27 and 2027-28 — and the price rises at the end: 12% for a 2025-26 or 2026-27 designation, 15% for 2027-28.
The election goes in the Self Assessment return. HMRC's stated deadlines are 31 January 2028 for 2025-26, 31 January 2029 for 2026-27 and 31 January 2030 for 2027-28, and you must be UK resident in the year of the return. Designated funds need not be brought into the UK, but no credit for foreign tax is available against the charge, and once the amendment window closes a designation cannot be withdrawn and there is no repayment.
Three other dates matter. Rebasing treats assets held on 5 April 2017 as acquired at market value that day, for disposals from 6 April 2025 by former remittance basis users. Business investment relief covers only investments made before 6 April 2028. The repealed domicile elections in the Inheritance Tax Act 1984 do not finally go until 6 April 2032, and charges on property excluded before 30 October 2024 are capped at £125,000 per whole quarter of the first period, then £5 million.
What filing now looks like
The four-year relief is claimed annually, not once, on the SA109 residence pages of the return. Claiming costs you the personal allowance, the capital gains annual exempt amount, and the married couple's, marriage and blind person's allowances, while the claimed income still counts towards adjusted net income.
Settled, and not
Settled: the remittance basis is gone; the four-year window needs ten clean years; inheritance tax runs on ten of the previous twenty years with a three-to-ten-year tail; the facility's rates and three tax years are in statute. Less settled: the Finance Act 2026 amendments to that facility are deemed always to have had effect, and the treatment of designated capital passed through trusts was rewritten in the same Act. Trust-holding families should read the provisions, not a summary written in 2025.
The direction is one-way. Residence is the connecting factor now, and every year of it will be counted again by someone who was not in the room. A family that starts with the calendar — twenty years of it, not four — will find this framework legible. One that moves first and counts afterwards will find the decade abroad was the asset it could not rebuild onshore.
