Question to the HM Treasury:

To ask the Chancellor of the Exchequer, what steps she is taking to provide increased incentives for non-domiciled individuals to remain in the UK.

On 6 April 2025 the outdated concept of domicile was removed from the tax system and replaced with a new residence-based regime, including a four-year foreign income and gains regime. The new regime includes the temporary repatriation facility (TRF) for individuals who have previously used the remittance basis to designate and pay tax at a reduced rate on foreign income and gains that arose prior April 2025.

The reforms to the tax treatment of non-domiciled individuals have been specifically designed to make the UK competitive, with a modern, simple tax regime that is also fair.

At Budget 2025, the government announced that it is introducing a cap on Inheritance Tax charges on trusts settled by former non-doms prior to Autumn Budget 2024. This reflects the significant amount of tax impacted individuals are expected to pay by remaining in the UK, as well as their wider economic contribution. This cap will apply to trust charges arising from April 2025.

At Budget 2025, the government also published the Finance Bill, which includes technical amendments to the legislation for the TRF. These include amendments to remove specific barriers to using the facility.