https://www.tax.org.uk/hmrc-one-to-many-emails-and-texts-foreign-income-and-gains 

HMRC have been using the "one to many" approach for many years, and I wrote about this previously (see link). What is clear is that there remains a lack of awareness among new arrivers to the UK as to how UK tax compliance actually operates. I saw clients, time and again, make assumptions about the previous remittance basis and a misconceived notion of its automatic application. I would not be surprised if a similar perception now exists around the new 4 year FIG regime which has heavily been marketed as a 4 year tax holiday on foreign income and gains, and in some respects, as being more attractive than its predecessor, albeit for a shorter window. But how does one actually benefit from this regime, when is it genuinely possible to benefit (don't assume), and what is the burden of increased compliance that comes with it?

The FIG regime allows certain categories of qualifying foreign income and gains to be relieved from UK tax, however, relief is never automatic. It must be actively claimed, year by year, via a validly submitted Self Assessment return.

A pitfall I see regularly with clients: eligibility depends on having been non UK resident, under the Statutory Residence Test, for the full ten consecutive tax years immediately before the year of return to UK residence. This is not simply a question of "was I a student in the UK", a single UK resident tax year anywhere inside that ten year run breaks the sequence entirely, and with it the whole four year relief, not merely the benefit attributable to that one year. Clients frequently fail to recognise a past year of UK residence as relevant, especially where they had no filing obligation at the time and so never thought of themselves as having been tax resident. The stakes here are higher than they first appear: this is a cliff edge test, not a sliding scale and it is exactly the kind of assumption driven misstep we come across. 

Claiming relief also requires each source of foreign income and each foreign gain to be separately identified and quantified in the return. HMRC's own guidance makes clear that an unquantified claim is invalid, and that understating the relieved amount simply forfeits the difference; there is currently no identified mechanism to top it up later. That quantification exercise necessarily increases HMRC's visibility into the underlying facts, at a time when HMRC's ability to cross reference offshore data via the Common Reporting Standard is now a routine, automated feature of its compliance landscape, rather than something confined to bespoke scrutiny of HNW taxpayers. Precision in the claim and robust contemporaneous record keeping to support both the ten year residence history and the quantified figures, since HMRC provides no advance certification of either is therefore not a nicety but the substance of a defensible claim.

On HMRC's communication approach itself: this particular campaign is genuinely well pitched in my opinion. It is educational in nature and expressly requires no action from recipients, delivered via an accessible video, clear links to HMRC guidance, and modern channels (text and email as well as post)! I believe it is a proportionate, low pressure way to raise awareness of a significant regime change, and compares favourably with some of HMRC's more demanding "nudge" campaigns that impose response deadlines. If you have any concerns about how the FIG regime, the ten year residence test, or the record keeping it requires may affect you, please do get in touch.