For decades, the UK remittance basis allowed non-domiciled individuals to keep foreign income and gains offshore, free from UK tax, provided those funds were not brought into the country. Many families built up substantial offshore wealth in this way. Some of that wealth has sat in overseas accounts, investment portfolios, and offshore structures for years, because bringing it to the UK would have triggered tax charges of up to 45 percent on foreign income and 24 percent on foreign gains.
The 2025 UK tax reforms changed everything. The remittance basis was abolished on 6 April 2025 and replaced with a residence based system. Alongside this major shift, the government introduced a three year window that offers former remittance basis users a rare opportunity to bring offshore wealth into the UK at a dramatically reduced rate. This window is called the Temporary Repatriation Facility.
If you have unremitted foreign income and gains sitting offshore, the next few years will define how much of that wealth you actually keep. This guide explains how the TRF works, who qualifies, how to claim it, and why the timing matters more than most people realise.
What is the Temporary Repatriation Facility?
The Temporary Repatriation Facility, commonly referred to as the TRF, is a transitional relief introduced as part of the UK’s move away from the non-domiciled tax regime. It allows eligible individuals to designate pre-6 April 2025 foreign income and gains and pay a flat rate of UK tax on those designated amounts, based on the qualifying overseas capital rules and without access to foreign tax credit relief against the TRF charge. Once tax has been paid under the TRF, the funds can be brought into the UK at any time, including after the facility closes, without any further UK tax charge on that original income or gain.
In plain terms, the TRF offers a defined path to bring previously unremitted foreign income and gains within the TRF regime so that, once designated and taxed, those amounts can be remitted to the UK without further UK tax on the designated element.
The facility runs from 6 April 2025 to 5 April 2028. That three year window is the only chance eligible individuals will have to use these reduced rates.
The TRF rates explained
The TRF applies two flat rates depending on when the designation is made.
A rate of 12 percent applies to designations made during the 2025/26 and 2026/27 tax years. A rate of 15 percent applies to designations made during the 2027/28 tax year. After 5 April 2028 the facility closes entirely, and any remittance of pre-6 April 2025 foreign income and gains would then be taxed at the applicable UK rates at the time of remittance, which can be as high as 45 percent for certain types of foreign income and up to 24 percent for capital gains, depending on the individual’s circumstances.
The difference is substantial. A person sitting on £500,000 of unremitted foreign income faces potential tax of £225,000 at the top marginal rate if that money is remitted without using the TRF. Under the 12 percent rate, the same amount attracts tax of £60,000. The TRF preserves £165,000 of wealth in that single example.
This is why planners are describing the next two tax years as a closing window rather than a distant deadline. The 12 percent rate only applies until 5 April 2027, and the entire facility ends a year later.
Who is eligible for the TRF?
The TRF is available to UK resident individuals who meet specific conditions. To qualify, you must have been taxed on the remittance basis in at least one tax year before 6 April 2025. This includes both individuals who formally claimed the remittance basis and those who used it automatically where allowed.
You must also have pre-6 April 2025 foreign income and gains that have not yet been remitted to the UK. The facility does not apply to income or gains arising on or after 6 April 2025. Those are treated under the new residence based rules and the separate four year Foreign Income and Gains regime for recent arrivers.
Non UK residents cannot use the TRF. If you have left the UK, you would need to return as a UK resident during the three year window to designate amounts, which raises other planning considerations that deserve specialist advice.
The facility also extends to certain distributions from offshore trusts, where the distribution is matched to pre-6 April 2025 income and gains of the trust. This is particularly relevant for long standing offshore family trusts with UK resident beneficiaries, and we cover this in more detail below.
How the designation process works?
Using the TRF is not automatic. It requires an active election made through the self-assessment tax return.
The claim is called a designation election. In your self-assessment return for the relevant tax year, you identify the specific amounts of pre-6 April 2025 foreign income and gains you wish to designate, and you pay the flat rate tax on those designated amounts.
The designation deadlines broadly follow the normal amendment window for the relevant self-assessment return, with the final date typically being the anniversary of 31 January following the end of the relevant tax year. For the 2025/26 tax year, the return is due by 31 January 2027 and can generally be amended until 31 January 2028. That means the last date to make a TRF designation for 2025/26 is typically 31 January 2028. The same pattern applies to 2026/27 and 2027/28 designations, with the final overall deadline being 31 January 2030 for the 2027/28 tax year at the 15 percent rate.
Once a designation is made and tax is paid, the designated amounts can be remitted to the UK without further UK tax on the designated element. You do not need to remit them immediately. You can leave them offshore and bring them to the UK years later, without any further UK tax charge on that original income or gain.
Importantly, a designation cannot generally be amended or withdrawn after the amendment window closes. Planning around which amounts to designate, and in which year, therefore needs to happen before you file.
What can be designated?
The TRF covers a broader range of assets than many people realise.
Cash held in offshore bank accounts that derives from pre-6 April 2025 foreign income and gains can be designated. Investments purchased with remittance basis protected funds can also be designated, as can non liquid assets such as overseas property or artwork acquired with foreign income or gains. In each case, the designation applies to the underlying income or gain used to acquire or fund the asset, not the asset itself.
Mixed funds, where an offshore account contains a combination of clean capital and remittance basis protected income and gains, need careful treatment. UK tax rules on mixed funds remain complex, and tracing the composition of an account is often the most technical part of any TRF claim.
Offshore trust distributions are also in scope in certain circumstances. Where a UK resident beneficiary receives a capital distribution from an offshore trust that is matched to pre-6 April 2025 income or gains, TRF treatment may be available, subject to the detailed matching rules and the classification of the amount as qualifying overseas capital. To benefit from the 12 percent rate, the relevant distribution needs to reach the beneficiary before 6 April 2027. Distributions made during 2027/28 fall under the 15 percent rate. This can represent a planning opportunity for some families with long established offshore structures, depending on the underlying trust analysis.
A worked example
To show how the TRF operates in practice, consider an illustrative scenario.
Ahmed has lived in the UK since 2012. He was taxed on the remittance basis for several tax years between 2015 and 2024. During that period, foreign investment income accumulated in an offshore investment account, and capital gains were realised within an offshore investment portfolio. By 6 April 2025, the combined pre-reform foreign income and gains sitting in his offshore accounts amounted to £800,000.
If Ahmed were to remit this money to the UK in 2026 without using the TRF, the foreign income element would be taxed at up to 45 percent and the gains at up to 24 percent. Depending on the split between income and gains, his UK tax bill on the full remittance could fall somewhere in the region of £220,000 to £330,000, based on top rates of 45 percent on foreign income and 24 percent on foreign gains.
If Ahmed instead makes a designation election for the full £800,000 in the 2025/26 tax year, he pays a flat 12 percent TRF charge. That is £96,000. The designated amount can then be remitted to the UK at any point, now or in the future, without any further UK tax on that £800,000 of original income and gains.
The saving in this illustrative example is between £124,000 and £234,000. The exact figure in any real case depends on the mix of income versus gains, the timing of designations, and whether mixed fund rules apply. This example is for illustration only and should not be relied on as tax advice for any specific circumstance.
Why the TRF matters beyond pure repatriation?
Some individuals use the TRF even when they do not intend to bring the funds to the UK immediately. The reason is practical. Once designated and taxed under the TRF, the amount can be remitted to the UK without further UK tax on that designated income or gain. It removes some of the uncertainty around having mixed or tainted funds offshore, which can complicate future investment decisions, succession planning, and trust distributions.
For individuals thinking about long term UK residence, using the TRF can be part of a wider plan that includes inheritance tax exposure, offshore trust structuring, and retirement planning. Under the new residence based inheritance tax regime, individuals who have been UK resident for 10 of the previous 20 tax years become Long Term Residents and are subject to IHT on their worldwide estate. Resolving the tax status of offshore wealth now can simplify that picture considerably.
The TRF also interacts with the four year Foreign Income and Gains regime available to new arrivers. Individuals returning to the UK after a period abroad may need to coordinate both reliefs to get the best outcome.
Common mistakes to avoid
Three issues come up repeatedly in TRF planning.
The first is assuming eligibility without checking the historical remittance basis position. Some individuals believe they used the remittance basis automatically, but the rules depend on unremitted foreign income and gains thresholds, claims made on tax returns, and whether an annual charge was paid in later years. A careful review of previous self-assessment returns is essential.
The second is ignoring the complexity of mixed funds. Where offshore accounts have seen multiple deposits, withdrawals, investments, and reinvestments, tracing the composition of the account can take considerable work. Getting this wrong can lead to designating amounts that do not actually qualify, or missing amounts that could have qualified.
The third is leaving it until the final year. The 15 percent rate in 2027/28 is 25 percent more expensive than the 12 percent rate available in 2025/26 and 2026/27. For large designations, that gap is material. Advisers are already seeing bottleneck risk as more families look to complete reviews before the 12 percent rate expires.
The TRF window is closing faster than it looks
April 2028 may sound distant, but in practice the useful planning window is much shorter. The 12 percent rate ends on 5 April 2027. Anyone wanting to maximise the benefit needs to identify eligible amounts, trace mixed funds, prepare the designation, and coordinate it with their self-assessment filing well ahead of that date.
For trust distributions, the timing pressure is even tighter. To benefit from the 12 percent rate on a distribution matched to pre-6 April 2025 trust income or gains, the distribution itself needs to reach the beneficiary before 6 April 2027. That requires coordination with trustees and often advance planning across multiple jurisdictions.
Frequently asked questions
Who can use the Temporary Repatriation Facility?
UK resident individuals who were taxed on the remittance basis in at least one tax year before 6 April 2025, and who hold unremitted foreign income and gains that arose before that date.
What are the TRF tax rates?
12 percent for designations in the 2025/26 and 2026/27 tax years, and 15 percent for designations in the 2027/28 tax year.
When does the TRF end?
The facility closes on 5 April 2028. Designations for the 2027/28 tax year must typically be made by 31 January 2030 in line with the normal amendment window for that year’s self-assessment return.
Can offshore trust distributions qualify for the TRF?
In certain circumstances, yes. Where a UK resident beneficiary receives a distribution matched to pre-6 April 2025 foreign income or gains, TRF treatment may be available, subject to the detailed matching rules and the relevant deadlines.
What happens if I miss the TRF deadline?
After 5 April 2028, any remittance of pre-6 April 2025 foreign income and gains will be taxed at the applicable UK rates at the time of remittance, which can be as high as 45 percent for certain types of foreign income and up to 24 percent for capital gains, depending on the individual’s circumstances.
Speak to HeirPlan about your TRF position
Every TRF case turns on the specific history of the individual’s remittance basis use, the composition of their offshore accounts, and the structure of any offshore trusts involved. Generic guidance only goes so far. The value of the TRF, and the cost of getting it wrong, both depend entirely on the detail.
At HeirPlan, we work with former non-doms, international families, and trustees to review offshore positions, identify eligible designations, coordinate with offshore structures, and make sure TRF claims are filed correctly and on time. We combine specialist UK tax expertise with a practical, clear approach that helps families make informed decisions about long term wealth planning.
If you have offshore income or gains that were built up under the remittance basis, the three year TRF window is the most significant transitional planning opportunity of its kind in recent UK tax history.
Book a free 30 minute TRF review with HeirPlan’s specialists. We will help you understand your eligibility, identify designation opportunities, and put together a plan that protects your wealth before the window closes. Contact us here or call our team to arrange your review.
This article provides general information only and does not constitute tax, legal, or financial advice. UK tax legislation is complex and subject to change. Individual circumstances vary, and you should seek specialist advice before acting on any information contained in this article.