The Temporary Repatriation Facility: A Practical Guide for Former Non-Doms

The abolition of the remittance basis on 6 April 2025 left hundreds of thousands of former non-domiciled individuals holding substantial stockpiles of offshore income and gains that had never been remitted to the United Kingdom. Remitting those funds under normal rules would trigger income tax at up to 45 per cent, or capital gains tax at up to 24 per cent — making repatriation economically unattractive for most.

The Temporary Repatriation Facility (TRF) was introduced to address this. For a limited three-year window, eligible individuals can designate pre-6 April 2025 foreign income and gains (FIG) and remit them to the UK at a flat, reduced rate. Understanding how the facility works — and whether it is worth using — is one of the most pressing tax-planning questions for affected individuals in 2026.

What Is the TRF?

The TRF allows individuals who used the remittance basis at any point before 6 April 2025 to designate stockpiled offshore income and gains (referred to as "FIG" in HMRC guidance) and pay a special flat rate of tax when those funds are remitted to the UK. The facility operates for the 2025-26, 2026-27, and 2027-28 tax years — meaning the window closes definitively on 5 April 2028.

The key rates are:

• 12 per cent on designated FIG remitted in 2025-26 and 2026-27
• 15 per cent on designated FIG remitted in 2027-28

This compares favourably with the income tax rate of 45 per cent that would otherwise apply to historic offshore income, or CGT at up to 24 per cent on gains — particularly for individuals with significant historical pre-2025 offshore accumulations.

Who Qualifies?

To use the TRF, you must:

1. Have been a remittance-basis user in any year before 6 April 2025
2. Now be resident in the UK (or be using the four-year FIG exemption as a new UK resident)
3. Have unremitted income or gains that arose before 6 April 2025 that you wish to bring to the UK

Individuals who were always taxed on the arising basis cannot use the TRF — they have no stockpile of offshore income to designate. Similarly, if you are non-UK resident and have no intention of bringing funds to the UK, the TRF may be irrelevant to your planning.

What Counts as Designatable FIG?

Broadly, the TRF covers:

• Foreign income that arose while on the remittance basis and was not remitted to the UK before 6 April 2025 — dividends, interest, rental income, employment income, business profits
• Foreign chargeable gains that arose while on the remittance basis and were not remitted
• Mixed funds held offshore, though specific ordering rules apply to determine what proportion represents income versus capital versus previously taxed amounts

Significantly, the TRF does not extend to income and gains that arose after 5 April 2025 — these are taxed under the new arising-basis rules that apply to all UK residents under the post-reform regime.

How the Designation Process Works

The TRF requires active designation on your Self Assessment tax return. You must specify the amount of FIG you are designating in a given year and pay the resulting TRF tax charge. The process is not automatic.

Importantly, you do not need to remit the full designated amount in the same tax year you designate it — once designated, FIG can be remitted freely in a later year without further tax liability. This gives flexibility: you might designate a large amount in 2026-27 (at 12 per cent) even if you intend to remit the funds in stages over several years.

You may also designate FIG without ever remitting it — for example, to cleanse offshore accounts and simplify future planning, or because you may wish to remit funds later without concern about whether they represent pre-2025 FIG.

Mixed Fund Cleansing — A Separate But Related Opportunity

The TRF interacts with a specific "cleansing" provision that was also introduced alongside non-dom reform. If you hold mixed offshore accounts containing a blend of income, gains, and clean capital, you were permitted a one-off window to segregate those funds into separate accounts. This cleansing window closed on 5 April 2026 for most purposes.

If you did not take advantage of the cleansing window, your ability to remit clean capital from mixed accounts is now constrained by the statutory ordering rules, which generally assume the most tax-inefficient composition is being remitted first.

Comparing TRF With "Do Nothing"

Former non-doms who are now resident in the UK but do not wish to remit offshore FIG face a practical reality: those funds remain offshore indefinitely. Under the post-reform regime, there is no longer a remittance basis charge — but equally, unremitted pre-2025 FIG does not simply disappear. It remains subject to income tax or CGT when (and if) it is ever brought to the UK.

For individuals who have no intention of bringing funds to the UK — perhaps because they plan to leave the UK and spend those funds abroad — the TRF may be irrelevant. For those who do want to access their offshore wealth in the UK (to purchase property, fund retirement, or consolidate assets), the TRF offers a material discount over waiting and remitting at full rates.

Planning Considerations for 2026

With one year of the 12 per cent window remaining (through 5 April 2027 — the 2025-26 year has already passed), the key questions for affected individuals are:

How large is the stockpile? Individuals who spent many years on the remittance basis and accumulated offshore income over decades may have very substantial FIG stockpiles. At 12 per cent, the TRF is significantly cheaper than the 45 per cent income tax rate — the maths favour designation even if you have no immediate remittance plans.

What is the composition? If the offshore funds are primarily gains rather than income, the benefit of the TRF over the normal CGT rate is smaller (the headline CGT rate for gains taxed after 2025 is 24 per cent for residential property, 18/24 per cent for other assets under current rates — seek advice on current rates as these have been in flux). The TRF at 12 per cent is still favourable but less dramatically so.

Will you remain UK resident? If you are planning to leave the UK again, the TRF may not be worth using — you could spend the offshore funds abroad without any UK tax obligation. However, if departure is uncertain, designating now locks in the 12 per cent rate regardless of what happens to future tax policy.

Liquidity and timing — The TRF tax is due via Self Assessment. If the amounts involved are large, you need liquid funds available to pay the charge. Designation without the means to pay is not sensible planning.

Common Mistakes to Avoid

• Failing to designate before the window closes — the TRF is not available retrospectively
• Confusing the TRF with the four-year FIG exemption for new UK arrivals (a separate regime)
• Assuming mixed funds can simply be remitted at the TRF rate without proper composition analysis
• Not obtaining professional advice before designation — errors on Self Assessment relating to FIG stockpiles can be costly to unwind

Rules Change — Act on Current Information

Tax legislation in this area has been particularly volatile. The non-dom reform was announced in the 2024 Autumn Budget, modified in Finance Act 2025, and HMRC published technical guidance that has itself been updated multiple times. The rates and mechanics described above reflect the position as of June 2026 — seek up-to-date advice before acting, as changes remain possible.

Investments and assets held offshore can fall as well as rise in value. The tax position depends on individual circumstances and professional advice should always be sought before making tax elections or designations.

How Global Investments Can Help

Global Investments works with internationally mobile individuals who are navigating the practical consequences of UK non-dom reform. Our advisers can help you assess whether your existing offshore accumulations make the TRF worthwhile, model the cost comparison between the TRF rate and your marginal rate on a standard remittance, and coordinate with your tax advisers to ensure designation is handled correctly on your Self Assessment return.

Whether you are currently UK resident or considering returning to the UK in the coming years, the TRF window is finite and requires active planning. Contact us to arrange a confidential review of your offshore structure and remittance position.