Thinking of moving to the UK? J.P Morgan Private Bank can help

The United Kingdom (“UK”) has long been an established destination for international business and investment, drawing individuals and enterprises from around the globe. In 2025, London ranked 4^th in the world as a destination for centi-millionaires and 7^th in the world for billionaires: the only city outside of the USA, China and Hong Kong to feature in the top 7.¹

The UK’s appeal is multifaceted, offering not only the chance to access world-class education through leading secondary schools, universities and research institutions, but also a rich tapestry of cultural, sporting and culinary experiences. Set against a business-friendly backdrop, strong legal structure and political stability, the country is an attractive choice for those seeking opportunities and a high standard of living.

A favourable framework

From 6 April 2025, the UK’s Resident Non-Domicile (“RND”) regime — a 200-year fixture of the personal tax system — was abolished and replaced with the new four-year Foreign Income and Gains (“FIG”) regime.

We consider it essential to evaluate FIG on its own merits. The purpose of this article is to provide a high-level summary of the benefits afforded to qualifying new residents.

J.P. Morgan does not provide tax or legal advice. We therefore recommend that individuals consult their tax advisors if they are considering taking advantage of the new regime.

Availability

The FIG regime is a residence-based test which replaces domicile as a relevant factor for income tax, capital gains tax (“CGT”) and inheritance tax (“IHT”) liability.

The FIG regime is potentially available to any individual who has not been UK tax resident under the UK’s Statutory Residence Test (“SRT”) in any of the previous 10 UK tax years, and who commenced UK tax residence from 6 April 2022.

This beneficial regime is not only available to foreign nationals becoming UK tax resident for the first time, but also to UK nationals who have been non-UK tax resident for the requisite period. Therefore, Brits who are considering returning to the UK after 10 years of absence should benefit — resulting in many contemplating a return.

Simplicity

The RND regime was synonymous with complexity. Individuals seeking to benefit often required complex structuring of their assets and bank accounts, with every movement of funds needing diligence and detailed advice from their tax advisor. These factors placed material restrictions on how beneficiaries of the RND regime could use and invest their wealth while in the UK.

By contrast, the FIG regime is simpler to operate. It offers generous relief by fully exempting eligible foreign income and gains from UK taxation for the first four years of tax residency, with no restrictions on how the funds are used. UK source income and gains are taxable during those four years of residency. New residents may find it easier to structure their financial affairs to benefit from the regime than was previously the case, potentially eliminating the need for multiple offshore accounts to segregate different pockets of their wealth. This flexibility allows those new residents to freely transfer funds to the UK to support investments and lifestyle needs without a UK tax charge.

Moreover, new UK residents will only be subject to IHT on their worldwide assets once they have been resident in the UK for 10 tax years. As such, those who wish to temporarily relocate to the UK can mitigate their IHT exposure and benefit from the new regime with minimal planning. Consequently, the FIG regime is likely to appeal to a broader audience, making relocation to the UK even more attractive.

Inward investment

It was historically the case for non-domiciled individuals that the use of untaxed foreign income and gains in the UK would typically trigger a UK tax charge, potentially at a rate of up to 45%. Now, those who benefit from the FIG regime may freely bring their untaxed assets to the UK without a tax charge, provided the funds they bring here did not arise during a period where they benefitted from the RND regime.

Qualifying parties are therefore no longer disincentivised from spending or starting new businesses in the UK. The attractiveness of the FIG regime may encourage individuals who are about to realise a significant liquidity event to relocate to the UK, given the ability to both sell their business and use the proceeds to fund their lifestyle tax-free.

While beneficiaries of the FIG regime may bring their untaxed foreign monies to the UK without a tax charge for 4 years, the same cannot be said for those who have funds that previously benefited from the RND regime. To allow for “legacy” RND monies to be brought to the UK more efficiently, the Temporary Repatriation Facility (“TRF”) has been introduced.

Broadly, the TRF allows those who have previously claimed the remittance basis to designate foreign income or gains that arose prior to 6 April 2025 to be remitted to the UK at a special lower tax rate. The applicable rate will be 12% for designations made for the tax years 6 April 2025–5 April 2026 and 6 April 2026–5 April 2027, increasing to 15% for designations made for the tax year 6 April 2027–5 April 2028. Crucially, designations can be made for both cash and non-liquid assets.

The TRF may also allow for distributions to be made to UK resident beneficiaries of offshore trusts at the reduced rate of tax. This applies to beneficiaries who have previously been subject to UK tax on the remittance basis, allowing for a potentially efficient wind up of structures which no longer meet their family’s objectives.

Under the RND regime, taxpayers were incentivised to retain their untaxed foreign income and gains outside of the UK and exclusively use it to fund overseas spending and investments. This position has been reversed. The barriers that prevented untaxed monies from being brought to the UK have been removed, with individuals now able to remit without incurring a tax charge.

Skilled talent

In addition to qualifying new residents not being subject to UK tax on foreign income and gains during their first four years of UK tax residence, HMRC have extended the availability of Overseas Workday Relief (“OWR”) for many employees coming to the UK.

For duties performed outside of the UK, eligible employees who benefit from OWR will not be subject to UK taxation on employment income during their first four years of residence. The relief available in each tax year is capped at the lower of 30% of the non-UK component of their employment income, or £300,000. This treatment must be claimed through an individual’s tax return by the normal 31 January filing deadline.

Given that individuals will be able to relocate to the UK and benefit from their non-UK investment income, gains and foreign employment income not being taxed, the country continues to be a very attractive destination for high-calibre professionals.

Low barriers to entry

In contrast to many other jurisdictions that offer favourable tax incentives, the FIG regime does not require taxpayers to pay an annual fee for access, nor agree their tax status with the local government ahead of arrival.

The FIG regime is available to taxpayers who come to the UK following a period of 10 consecutive years of non-UK tax residence. As such, the attractiveness of the FIG regime is not limited to ultra-high-net-worth individuals — the spectrum of people who may benefit can be much more widely drawn.

It is worth noting that individuals opting for taxation under the FIG regime must quantify the foreign income and gains for which they are claiming relief and include this information in their tax return. From 6 April 2025, all UK tax residents will be obliged to report their worldwide income and gains regardless of whether these amounts are subject to tax. The UK is not alone in adopting this position with regards to disclosure.

Rebasing of capital assets

Individuals who previously benefitted from the RND regime may be able to rebase their personally held foreign assets, effectively wiping out a portion of any gain without incurring a tax charge. On the face of it, this opportunity may appear incredibly generous, but there are several caveats. The rebasing date is 5 April 2017, meaning that the assets must have been held since then, and the individual cannot have been deemed UK domiciled on or before 5 April 2025. This relief is however likely to continue to be beneficial to those that have held material stakes in private family businesses for many years, and/or overseas property portfolios.

How J.P. Morgan Private Bank can help you relocate to the UK

The new FIG regime should be attractive to many internationally mobile individuals who wish to enjoy the tax-friendly opportunities the UK can provide them and their families. Many find obtaining an appropriate visa to relocate to the UK challenging, so appropriate specialist advice on this aspect will be required. 

Moving to a new country can be both an exciting and challenging experience. At J.P. Morgan, we partner with our clients to help facilitate their journeys. We stand ready to help you navigate your transition, ensuring that you are equipped with the necessary insights and information to make informed decisions.

Real-estate explorer: Cotswolds

While central London boasts some of the country's most expensive real estate, have you considered the Cotswolds? Offering a serene country oasis within commuting distance, featuring luxury estates with spacious acreage, a vibrant restaurant scene, private members clubs, and a thriving international community.

This material has been prepared for informational purposes only, and is not intended to provide, and should not be relied on for tax, legal and accounting advice. JPMorganChase and its affiliates do not provide tax, legal or accounting advice and are not responsible for any adverse tax consequences or liabilities. You should consult your own tax, legal and accounting advisors before engaging in any transaction.