| For whom | UK residents who used the remittance basis for at least one year in the past |
| What | foreign income and gains from before 6 April 2025, and money of unclear origin |
| Rate | 12% in 2025/26 and 2026/27, 15% in 2027/28 |
| How | designation in the tax return, SA109 pages |
| Afterwards | designated capital can come to the UK at any time without further tax |
| Basis | Finance Act 2025 |
| Updated | November 2026 |
What the TRF is about
Until 5 April 2025 non-domiciled residents, the classic non-doms, could use the remittance basis: foreign income and gains were taxed in the UK only when brought to the UK. Since 6 April 2025 the remittance basis has been abolished. What is left of it is described in our piece on the end of non-dom status.
The problem: the old income and gains from those years that were never brought to the UK remain tainted. Bring them in today and they are taxed at the normal rates, up to 45 percent on income, and foreign dividends even at the normal rather than the lower dividend rates. Anyone carrying on their life in the UK sits on wealth they cannot use without paying dearly.
The Temporary Repatriation Facility, or TRF, is the time-limited way out. You designate such old amounts in your tax return and pay a flat one-off charge of 12 percent in 2025/26 and 2026/27. After that the money is free: bring it to the UK now, later or never, and no further tax arises. You do not have to transfer anything to get the special rate.
Rates and deadlines
The TRF covers exactly three tax years. A designation is treated as made at the start of the tax year.
| Tax year | Rate | Designate by |
|---|---|---|
| 2025/26 (6 April 2025 to 5 April 2026) | 12% | 31 January 2028 |
| 2026/27 (6 April 2026 to 5 April 2027) | 12% | 31 January 2029 |
| 2027/28 (6 April 2027 to 5 April 2028) | 15% | 31 January 2030 |
HMRC, HS264 section 4; RDRM73320
Who can use the TRF
Two conditions: you are UK resident under the statutory residence test in the tax year you designate for, and you used the remittance basis for at least one tax year in the past. You need not have claimed it expressly. It is enough that it applied automatically, for example because your unremitted foreign income in a year was under £2,000.
If you are not UK resident in a TRF year, you cannot designate for that year. That affects many who left the UK after the reform: they have the TRF only if they are resident again in 2025/26, 2026/27 or 2027/28. And only the person who would be taxable on a remittance can designate, not the spouse who happens to hold the money in their account.
What you can designate
HMRC calls it qualifying overseas capital. It includes:
- Foreign income and gains from years before 6 April 2025 in which the remittance basis applied, whether still abroad or brought to the UK during the TRF years.
- Money abroad whose origin you can no longer reliably trace.
- Capital payments and benefits from non-UK trusts matched to income or gains of the trust structure from before 6 April 2025. No capital gains tax supplement arises on such designated capital payments either.
- Assets abroad bought with such old amounts, such as a property or a portfolio. You do not have to sell them.
- Old amounts sitting in exempt property or in a UK company under Business Investment Relief, without unwinding the investment.
How to designate
Designation is an election in the Self Assessment return, not a separate application.
- 1
1. Take stock
Go through every account, portfolio and asset that stems from income and gains of the remittance basis years, including joint accounts, mixed funds and trust payments.
- 2
2. Fix the amount
You need not designate everything; partial amounts are expressly allowed. Income is converted at the rate on the day of designation, which is the start of the tax year; gains at the rate on the day of disposal.
- 3
3. Declare
On the SA109 pages you make the election in box 50, the amounts go in boxes 51 and 52 (52 for trust payments), and box 54 shows how much was brought to the UK in the same year.
- 4
4. Pay and keep records
The charge is collected like income tax but does not appear in your taxable income and changes neither bands nor payments on account. Keep the paperwork, so you can show later that a transfer was designated capital.
The traps
First, paying. If you pay the TRF charge to HMRC from a foreign account holding undesignated old money, that payment itself is a normal, fully taxable remittance to the UK. There is no exemption like the old one for the remittance basis charge. So pay from designated money or from capital that was never tainted.
Second, foreign tax. The TRF charge is a charge on capital, not an income or capital gains tax. There is no credit for foreign tax, and a tax treaty that covers only taxes on income and gains does not apply to it. Amounts already taxed abroad go into the designation net of the foreign tax. If you received foreign dividends before 6 April 2016, designating them also loses the old dividend tax credit.
Third, the calendar. In 2027/28 the rate rises to 15 percent, and then the TRF is over. Whatever is not designated by then is taxed again at normal rates on every remittance. Budget 2026 of 28 October 2026 did not extend the TRF, though the government will keep the whole residence-based system under review.
TRF or FIG regime?
They do not exclude each other; they cover different periods. The four-year FIG regime relieves only income and gains from 6 April 2025, and only for newcomers after at least ten years outside the UK. It expressly does not help with old amounts from remittance basis years, even if you return after ten years. HMRC itself points to the TRF for those.
For a former non-dom living in the UK today that means: new foreign income under the rules since April 2025, old foreign money through the TRF. If the old wealth sits in a trust, the structure needs a review anyway; more in our piece on trusts after the reform.
Frequently asked questions
Do I have to bring the designated money to the UK during the TRF years?
No. You pay the charge on the designated amount and can bring it to the UK at any time afterwards without further tax, even years later.
What does the TRF cost by comparison?
For 2026/27, 12 percent of the designated amount. Bring the same old amounts in without designation and the normal rates apply: up to 45 percent on income and up to 24 percent on gains.
I never claimed the remittance basis. Can I still use the TRF?
Possibly. It is enough that the remittance basis applied to you automatically in a year, for example because unremitted foreign income was under £2,000.
I live outside the UK again now. Can I designate?
Only for a TRF tax year in which you are UK resident under the statutory residence test. As a non-resident you cannot designate for that year.
How do I handle a mixed fund?
If you designate amounts in a mixed fund, the designated TRF capital is treated as coming out first on a remittance, whatever year it stems from. That makes mixed funds much simpler, but it needs clean records.
Sources: GOV.UK: HS264 Remittance of pre-6 April 2025 foreign income and gains, and the TRF; HMRC Manual: RDRM71000 Temporary repatriation facility, introduction; HMRC Manual: RDRM72100 Qualifying overseas capital; HMRC Manual: RDRM73200 Eligibility; HMRC Manual: RDRM73320 Time limits; HMRC Manual: RDRM73400 TRF charge; GOV.UK: HS266 Foreign income and gains (FIG) regime (2026); GOV.UK: Budget 2026
