The Temporary Repatriation Facility (TRF) Explained

The Temporary Repatriation Facility is a time-limited concession that lets former remittance-basis users pay a low flat charge to clear the tax on foreign income and gains they built up before 6 April 2025 but never brought to the UK. Once an amount is designated and the charge is paid, that money is settled for UK tax purposes and can be transferred to the UK whenever the owner chooses.

It exists because the remittance basis was abolished from 6 April 2025. Before that reform, non-domiciled individuals could keep foreign income and gains outside the UK indefinitely and pay no UK tax until they remitted them. Many people therefore hold large pools of historic offshore FIG that would face tax of up to 45% on the day they bring it home. The TRF offers a discounted, predictable exit from that position, but only for a fixed three-year window.

The TRF is for former remittance-basis users who are UK resident in the year they designate and who hold qualifying overseas capital, meaning pre-6 April 2025 foreign income and gains that arose while they were subject to the remittance basis and remain unremitted. You do not need to have formally claimed the remittance basis every year to qualify.

HMRC's guidance confirms that, for 2008/09 onwards, being subject to the remittance basis means sections 809B, 809D or 809E of ITA 2007 applied to you, even if you never made a formal claim. Eligibility was also extended to certain offshore-trust settlors and beneficiaries and to mixed-fund situations. Because the boundary is wider and more technical than many people assume, it is worth checking your history rather than ruling yourself out.

Typical clients who benefit include:

• Former non-doms with offshore accounts holding years of untaxed foreign salary, dividends, interest or capital gains.
• People who used the remittance basis even once since 2008/09 and still hold unremitted FIG from before 6 April 2025.
• Settlors or beneficiaries of offshore trusts with qualifying overseas capital who fall within the extended rules.
• Anyone with a mixed fund (clean capital tangled together with income and gains) who wants certainty before bringing money to the UK.

The two are easy to hold apart once you fix the distinction in mind: the TRF is for OLD money and the 4-year FIG regime is for NEW money. They serve different people and different pots of cash, and clients confuse them constantly.

• The TRF cleans up historic, pre-6 April 2025 foreign income and gains of people who previously used the remittance basis. It applies a 12% to 15% charge to bring that legacy money onshore.
• The 4-year FIG regime exempts the new foreign income and gains of recent arrivals to the UK in their first four years of UK residence, so eligible new arrivals pay no UK tax on qualifying foreign income and gains arising in that window.
• A long-standing UK resident who was a non-dom does not qualify for the FIG regime on new income, but may well qualify for the TRF on their old pool. A brand-new arrival uses the FIG regime, not the TRF.
• It is possible to be relevant to both over time: someone could shelter new income under the FIG regime while using the TRF to deal with money built up before April 2025.

If you are unsure which applies to you, our guide to the fig-regime-uk sits alongside this one and the two are best read together.

The TRF charge is a flat percentage of the amount you designate, and that percentage rises across the window: 12% for 2025/26, 12% again for 2026/27, then 15% for 2027/28. After 5 April 2028 the facility closes and the normal rules return, where a remittance of foreign income can be taxed at up to 45%.

The practical message is that the cost of designation goes up, not down, the longer you wait, and it disappears entirely once the window shuts. For 2026/27, the year this guide is framed to, the rate is still 12%. Waiting until 2027/28 lifts the charge to 15%, a 3 percentage point premium on the same money. Missing the window altogether can mean the difference between 12% and 45%.

Because the rate is fixed and known in advance, the TRF turns an uncertain future tax bill into a planned, budgeted figure. That certainty is one of its biggest advantages.

You designate qualifying overseas capital through your self-assessment return for the relevant year, reporting the amount designated and paying the flat charge as part of your tax for that year. Designation is an active choice you make on the return; it does not happen automatically.

Crucially, you do not have to physically move the money to the UK during the window to benefit from the low rate. You can designate while the funds stay offshore, pay the charge, and remit later, whether that is next year or after the facility has closed. Once an amount is designated and charged, it is available for remittance at any future time without further UK tax.

Practically, that means careful record-keeping. You need to identify which historic income and gains you are designating, keep evidence of the source and the charge paid, and track the now-cleared funds separately so a future transfer to the UK is clean and demonstrable. Where money is held in a mixed fund, untangling the layers correctly is the technical heart of the work.

There is no exemption for money brought to the UK to pay the TRF charge, and this is the single most expensive mistake we see, so we state it plainly. Unlike the old remittance basis charge, which had a specific carve-out for funds used to pay it, the TRF has none.

That means if you pay the TRF charge using undesignated pre-April-2025 foreign income or gains, you have made an ordinary taxable remittance of that money, taxed at normal rates of up to 45%. You would, in effect, trigger a full-rate tax bill in the very act of trying to access the discounted rate. This nuance is confirmed by major firms including RSM and Deloitte, and is not spelled out on the face of the gov.uk helpsheet.

There are two safe ways to fund the charge:

• Designate the funds you use to pay the charge, so they are themselves cleared at the TRF rate before they reach the UK.
• Pay from clean capital, meaning money that is not foreign income or gains (for example, capital you held before becoming UK resident, or properly segregated clean funds).

Getting this wrong can wipe out the entire benefit of the facility, which is exactly why the funding route should be planned before any payment is made.

A worked example shows how decisive the timing is. Assume a former remittance-basis user holds GBP 500,000 of unremitted foreign income in an offshore account, all of which arose before 6 April 2025 and qualifies for the TRF. The figures below are simplified to show the arithmetic and are not advice. The 45% comparison assumes the whole pool is foreign income; any capital-gains element would instead be taxed at CGT rates (up to 24%) on a normal remittance, not 45%.

• Designating the full GBP 500,000 in 2026/27 at the 12% rate: charge of GBP 60,000 (500,000 x 12%).
• Designating the same GBP 500,000 in 2027/28 at the 15% rate: charge of GBP 75,000 (500,000 x 15%). Waiting one year costs an extra GBP 15,000.
• Bringing the money to the UK after the window closes with no designation, taxed as a remittance of foreign income at 45%: GBP 225,000 (500,000 x 45%).
• Net to the UK after a 2026/27 designation: GBP 500,000 less the GBP 60,000 charge, leaving GBP 440,000 available to remit free of further tax.

On these assumptions the 2026/27 route is GBP 165,000 cheaper than remitting at 45% later, and GBP 15,000 cheaper than designating a year later. The charge in this example would need to be paid from designated funds or clean capital, not from the undesignated GBP 500,000, to avoid triggering a separate full-rate remittance.

The TRF is open for three tax years and three only: 2025/26, 2026/27 and 2027/28, and there is no indication of an extension. Once 5 April 2028 passes, the reduced rates are gone and any later remittance of historic FIG falls under normal rules at up to 45%.

Because designation runs through self-assessment, there is real lead time involved. You need to identify and quantify the qualifying capital, work through any mixed-fund analysis, decide the right amount to designate, plan how the charge will be funded, and reflect it all correctly on the return by the filing deadline (31 January following the tax year). For 2026/27, that points to action well before 31 January 2028. Leaving it to the final year both raises the rate to 15% and compresses the time to do the work properly.

We handle TRF planning end to end on a fixed fee agreed upfront, so you know the cost before we start. Our work typically covers confirming eligibility (including the wider rules for past remittance-basis users and offshore-trust connections), quantifying your pre-6 April 2025 qualifying capital, untangling mixed funds, modelling the 12% versus 15% timing decision against your circumstances, structuring how the charge is funded so it does not itself become a taxable remittance, and completing the designation correctly on your self-assessment return.

If you previously used the remittance basis and still hold offshore income or gains from before April 2025, the sensible first step is a short review to confirm whether the TRF is worth using and at what cost. The window closes on 5 April 2028 and the funding trap is unforgiving, so booking that review while the rate is still 12% is the cautious choice. Get the fixed-fee estimate first, then decide.