The 4-Year FIG Regime: What New UK Residents' Portfolios Need From Advisers
From 6 April 2025 the remittance basis was replaced by the 4-year foreign income and gains (FIG) regime. A qualifying new UK resident can claim relief from UK tax on foreign income and gains for their first four tax years of residence. For an adviser, the question is practical: which parts of the client's portfolio are foreign, which years are left, and what the claim gives up. This note covers eligibility, what a claim covers and costs, and a worked example.
Who qualifies
HMRC's manual RFIG44000 and helpsheet HS266 set the conditions. In the first year, the client must be UK resident, not have been UK resident for at least 10 consecutive tax years immediately before, be at least 10 years old at the start of the tax year and not sit in either House of Parliament. The later qualifying years are the three tax years immediately following the first. Treaty non-residence and split-year treatment are ignored for these tests: a split year counts as a full year of UK residence.
HMRC's guidance adds that unused years cannot be rolled over to a later year. A client who arrived before 6 April 2025 can be a qualifying new resident for the years of their window from 2025-26 onwards. RFIG44000's examples: arriving in 2024-25 gives claims for 2025-26, 2026-27 and 2027-28 but not 2028-29; arriving in 2023-24 gives only 2025-26 and 2026-27. Foreign income and gains that arose before 6 April 2025 cannot be relieved under the regime.
What a claim covers
- Foreign income. RFIG45100 lists the qualifying foreign income under ITTOIA 2005 s.845H. For a portfolio the relevant items are dividends from non-UK resident companies, interest (such as on a foreign bank account) and offshore income gains (reg. 17 of the Offshore Funds (Tax) Regulations 2009). Relevant foreign earnings are not qualifying foreign income.
- Foreign gains. A qualifying foreign asset gain is a chargeable gain on the disposal of an asset situated outside the UK, by the situs rules in TCGA 1992 ss.275 to 275C (RFIG45500).
- Source by source. Claims are made on the Self Assessment return for the tax year, for each amount of foreign income from each source, with separate claims for income and for gains (RFIG42100).
- Bringing money in. HS266 says relieved income and gains can be brought to the UK with no tax liability when they are.
Whether a given holding's income or gain is foreign is a source and situs question, settled holding by holding. UK company dividends and gains on UK-situated assets are not relieved. RFIG45100 names offshore income gains but does not separately mention reported income from reporting funds, so confirm how a client's excess reportable income is treated before relying on the claim for it.
What a claim costs, and when it is due
- Allowances. Claiming removes the year's personal allowance and Capital Gains Tax annual exempt amount, along with other allowances and reliefs HS266 lists (blind person's allowance, married couple's and transferable allowances among them).
- Losses. Foreign income or capital losses cannot be claimed in a year in which relief is claimed, and cannot be carried forward or back (HS266).
- Deadline. By the anniversary of 31 January following the tax year: for 2025-26, 31 January 2028 (HS266). The amounts are claimed in the relevant supplementary pages.
A worked example (illustrative)
A client became UK resident on 1 June 2024 after twelve years abroad, so 2024-25 is their first year and the window runs to 2027-28; relief is available from 2025-26. In 2026-27, the current tax year, two years of relief remain, this one included. They are a higher-rate taxpayer on UK salary and have no UK gains. In 2026-27 their foreign brokerage account pays £6,000 of dividends from non-UK companies, and they sell non-UK shares for a gain of £30,000. Foreign withholding tax and its credit are left aside.
| 2026-27 | Without a claim | UK tax |
|---|---|---|
| Foreign dividends | (6,000 − 500 allowance) × 35.75% | £1,966.25 |
| Foreign gain | (30,000 − 3,000 exempt amount) × 24% | £6,480.00 |
| Total without a claim | £8,446.25 | |
| With a claim on both: UK tax on these amounts | £0 | |
Rates and allowances are HMRC's for 2026-27 (dividends, Capital Gains Tax). The claim costs the exempt amount, of no use here without UK gains, and the personal allowance, whose value is the allowance times the client's marginal rate for the year. On these figures the claim is ahead if that value is less than £8,446.25. A £10,000 foreign loss in the same year would be lost if the claim is made, which can tip the comparison.
What Borderfolio shows
- The window. For a UK-resident client with a "resident since" date on the profile, the finding "4-year foreign income and gains (FIG) regime" shows the first and last tax year of the window, the year relief starts (2025-26 for earlier arrivals), the years left and a tax-year timeline marking past, current and future years.
- The condition it cannot see. Ten prior years of non-residence are not on file, so the finding asks the adviser to confirm them rather than asserting eligibility.
- The cost of claiming. The notes state that a claim costs the year's tax-free allowances and that unused years cannot be carried forward.
- Where. On the client's Cross-Border page and in the review report, with HMRC's guidance and HS266 cited (cross-border findings).
Not modelled: whether to claim, and the relief itself, which is a year-by-year judgement; which holdings' income and gains are foreign; foreign losses; the claim deadline. The window is counted from the tax year containing the arrival date, and split years are not applied separately.
Sources: HMRC, Check if you can claim the 4-year FIG regime, HMRC HS266 (2026), RFIG44000, RFIG45100, RFIG45500, RFIG42100, HMRC, Tax on dividends, HMRC, CGT rates and allowances.
Frequently asked questions
Who qualifies for the 4-year FIG regime?
A UK resident who was not UK resident for at least 10 consecutive tax years immediately before their first year of residence, for that year and the three tax years after it (HMRC RFIG44000, HS266).
Can a client who arrived before April 2025 still claim?
Yes, for the years of their window from 2025-26 onwards. Someone who arrived in 2024-25 can claim for 2025-26 to 2027-28; foreign income and gains arising before 6 April 2025 cannot be relieved under the regime (RFIG44000).
What does a FIG claim cost?
The year's personal allowance and Capital Gains Tax annual exempt amount, among other allowances, and foreign losses cannot be claimed in a year of claim (HS266).
When must the claim be made?
On the Self Assessment return, by the anniversary of 31 January following the tax year: 31 January 2028 for 2025-26 (HS266).