Long-term UK residence and the FIG regime

From 6 April 2025 the old domicile machinery is gone, and two residence-based rules replace it — one for IHT, one for income tax and CGT. Rule one, for IHT: an individual who has been UK resident in at least 10 of the 20 tax years before the chargeable event is a LONG-TERM UK RESIDENT, and long-term residence pulls their WORLDWIDE assets into IHT; anyone else is within IHT on UK assets only. The status has a tail — leave the UK after qualifying and worldwide exposure runs on for between 3 and 10 further years, scaled to how long you were resident — and a reset: 10 consecutive non-resident years clear the slate. The exam syllabus itself now assumes every individual is a long-term UK resident unless the question says otherwise, so this vocabulary IS the default. Rule two, for income tax and CGT: the FIG regime. A qualifying new resident — first 4 tax years of UK residence, arriving after at least 10 consecutive non-resident years — can claim, year by year, 100% relief on chosen foreign income and gains. No remittance test, no remittance-basis charge; the price is that year's tax-free allowances, BOTH the personal allowance AND the CGT annual exempt amount. Finally the two rules meet at the spouse exemption: transfers from a long-term UK resident to a spouse who is not one are exempt only up to £325,000; the reverse direction is exempt without limit.