If you were a UK remittance-basis user before the non-dom reforms of 6 April 2025, you likely have foreign income and gains sitting offshore that you never brought into the UK precisely to avoid UK tax on them. The Temporary Repatriation Facility (TRF) is the government's time-limited offer to let you bring that money home at a flat, reduced rate instead of full income or capital gains tax rates. The catch is the clock: the facility runs for only three tax years, the rate is 12% for the current 2026-27 year, and it rises to 15% for the final year, 2027-28. For high-net-worth Americans and other former non-doms in the UK, this is one of the more concrete, dated planning windows in the whole reform — and it is closing.
What the Temporary Repatriation Facility actually is
From 6 April 2025 the UK replaced the old remittance basis with a new residence-based regime for foreign income and gains. Anyone who previously claimed the remittance basis is likely sitting on a pool of pre-6 April 2025 foreign income and gains that was never remitted — and under the old rules, bringing it into the UK would have meant paying tax on it at full rates, sometimes decades after it arose. The TRF is a transitional relief: designate ('nominate') qualifying pre-6 April 2025 foreign income and gains and pay a flat TRF charge instead of the income tax or capital gains tax rate that would otherwise apply.
According to HMRC's TRF manual (RDRM71000), the facility is available for three tax years only: 2025-26, 2026-27 and 2027-28. Once those years pass, the facility closes and any later remittance of pre-2025 funds reverts to being taxed under the ordinary remittance rules that still apply to unrelieved amounts.
The rate that matters right now: 12%, rising to 15%
The TRF rate is 12% for both 2025-26 and 2026-27 — so the current tax year, 2026-27, is still at the lower rate. For the final year, 2027-28, the rate rises to 15%. There is no year in between at an intermediate rate; it is 12% for two years, then 15% for one, then the facility is gone entirely.
Why this matters more than the headline percentage suggests
Twelve or fifteen per cent sounds like a narrow band, but the comparison that matters is not 12% versus 15% — it is 12-15% versus the alternative of not using the TRF at all. Foreign income remitted outside the facility is taxed as income at up to 45%; foreign capital gains remitted outside the facility are taxed at up to 24%. Against those benchmarks, even the higher 15% TRF rate is a significant discount, and the 12% rate available right now is markedly better still. For a HNW individual with a meaningful pool of legacy offshore gains, the difference between designating this year and designating next year can run into real money on even a moderate sum.
Designation, not remittance, is the trigger
A subtlety that catches people out: what fixes the TRF rate is the tax year in which you designate the qualifying income or gains, not necessarily the year you physically move the cash. You nominate an amount of pre-6 April 2025 foreign income and gains on your Self Assessment return for the relevant tax year, pay the TRF charge on it, and that designated amount then becomes 'cleansed' — you can remit it to the UK later without further UK tax. This means the decision to lock in the current 12% rate is a filing decision made by reference to this tax year, even if the actual transfer of funds happens somewhat later. HMRC's helpsheet HS264 sets out the mechanics of designation and remittance.
What qualifies for the TRF
- Foreign income and gains that arose before 6 April 2025 and were taxed on the remittance basis (i.e. never brought to the UK and taxed at the time).
- You must have been a remittance-basis user for at least one tax year before 2025-26 for the relevant income/gains to qualify.
- Certain categories are excluded or treated differently — offshore income gains and some trust distributions have their own rules, so the underlying source of the funds needs checking carefully.
- The designation is made through your Self Assessment return for the tax year of designation, alongside the TRF charge.
Foreign tax credits and the TRF
One further wrinkle for cross-border individuals: foreign tax paid on the same income or gains does not straightforwardly offset the TRF charge in the way a normal foreign tax credit would offset income tax. HMRC's manual on TRF and foreign tax credits (RDRM73340) sets out the limited relief available, which is narrower than the double-tax relief you would expect on ordinarily taxed income. For US citizens who may also have paid US tax on the same underlying income at the time it arose, this interaction needs modelling before you designate — the TRF charge and any US credit position do not automatically align.
How the TRF interacts with the new FIG regime
The TRF sits alongside the new Foreign Income and Gains (FIG) regime that replaced the remittance basis — the FIG regime governs your NEW foreign income and gains going forward (broadly, a 4-year window of relief for genuinely new arrivals), while the TRF is specifically about CLEANING UP legacy, pre-2025 amounts you already have sitting offshore. They are two different tools solving two different problems, and HMRC's guidance on the interaction (RDRM76100) confirms they operate independently — using one does not disqualify you from the other, but they need to be planned together as part of a single strategy for anyone who was previously non-domiciled.
A worked illustration
Suppose you have £500,000 of pre-2025 foreign gains sitting in an offshore account, never remitted, from your time as a remittance-basis user. Designating that amount in 2026-27 at 12% costs £60,000 in TRF charge, after which the funds are cleansed and can be brought to the UK freely. Wait until 2027-28 to designate the same £500,000, and the charge rises to £75,000 — £15,000 more for identical funds, purely for waiting one more tax year. Miss the facility altogether, and remitting those same gains later (assuming they retain their character as gains) could be taxed at up to 24% — £120,000 — twice the 2026-27 TRF cost.
Why HNW Americans in the UK are especially affected
Long-term US expats who were UK non-doms often built up exactly this kind of offshore pool — US brokerage gains, foreign rental income, or investment income never remitted to the UK because the remittance basis made that unnecessary. The abolition of the remittance basis from April 2025 means that planning assumption no longer holds, and the TRF is the one-time tool to deal with the legacy position cleanly. Because these individuals are also US taxpayers on worldwide income regardless of remittance, the TRF decision has to be made in the context of the existing US position, not the UK position alone — which is exactly the kind of cross-border modelling a generalist UK adviser will not naturally do.
What to do before the window closes
- Quantify your pool of pre-6 April 2025 unremitted foreign income and gains, split by category (income vs. gains vs. offshore income gains).
- Confirm you were a remittance-basis user for at least one year before 2025-26.
- Model the TRF charge at 12% now versus 15% in the final year against your actual figures.
- Check the interaction with any US tax already paid on the same income, and with your FIG regime position if you are a newer UK arrival.
- Decide the amount and timing of designation with your Self Assessment return for this tax year, not next.
The window is real and it is closing
The Temporary Repatriation Facility is a genuinely valuable, dated opportunity — not a permanent feature of UK tax. With one tax year left at 12% before the rate rises to 15%, and the whole facility gone after 2027-28, this is a rare case in cross-border tax planning where the calendar itself creates the deadline. For HNW Americans and other former non-doms with meaningful legacy offshore funds, a US/UK tax specialist can quantify what you hold, model the TRF charge against your alternatives, and coordinate the designation with your wider US position before the lower rate disappears.
