The UK Temporary Repatriation Facility lets former remittance basis users pay a flat 12 percent charge on foreign income and gains that arose before 6 April 2025. The 12 percent rate applies to amounts designated in a 2025-26 or 2026-27 return. For 2027-28 it rises to 15 percent, and after 5 April 2028 the facility closes.
What the Temporary Repatriation Facility is
It is a three-year window to clean up old offshore money at a reduced rate. HMRC's Residence, Domicile and Remittance Basis Manual states that from 6 April 2025 it is no longer possible to use the remittance basis, and that the facility is available for a fixed period of 3 years: the 2025-26, 2026-27 and 2027-28 tax years.
Before April 2025, a non-domiciled UK resident on the remittance basis paid UK tax on foreign income and gains only when they were brought to the UK. Pools of unremitted money built up offshore. Under the new rules those pools stay taxable whenever they are remitted, at normal rates, unless they are designated under the facility. For the rules that now apply to new arrivals, see our note on the UK foreign income and gains regime.
What it costs
The rate is set in the statute. Schedule 10 to the Finance Act 2025 fixes the charge at 12 percent of qualifying overseas capital designated in a return for 2025-26 or 2026-27, and 15 percent for amounts designated in a return for 2027-28. Finance Act 2026 made technical amendments to Schedule 10, mostly for trust and transfer of assets abroad cases. The rates were not changed.
For scale, a simple illustration using gov.uk's published bands: income above £125,140 is taxed at the additional rate of 45 percent in 2026-27. On £500,000 of old foreign employment income:
- Designated in the 2026-27 return · 12 percent · £60,000
- Designated in the 2027-28 return · 15 percent · £75,000
- Remitted as ordinary income after the window, all in the additional rate band · 45 percent · £225,000
HMRC describes the TRF charge as a charge on capital, not a tax on income or capital gains. Where a double taxation convention covers only taxes on income and gains, the charge falls outside it. It also sits outside the individual's total income, so a designation does not affect adjusted net income, tax bands or payments on account, according to HMRC's guidance on making a designation.
Who qualifies
HMRC's eligibility guidance sets three conditions. The individual must be UK resident under the statutory residence test in the tax year of designation, must have been subject to the remittance basis for at least one tax year, and must have qualifying overseas capital to designate.
The remittance basis condition is wider than it looks. It is met if the remittance basis applied automatically, for example because unremitted foreign income and gains for the year were under £2,000, not only where it was formally claimed. Only the person who would be taxed on the remittance can designate. A spouse or child who physically brings the money in cannot designate it for them.
Residence is the hard gate. Someone who is non-UK resident in a tax year cannot designate in that year at all. For how UK residence is counted against other countries, see the 183-day rule compared across four countries, and the United Kingdom country guide.
What money qualifies
The facility covers foreign income and gains that arose before 6 April 2025 in a year the individual was on the remittance basis, plus amounts held overseas where the source is uncertain. HMRC states that designations are not limited to money held overseas: overseas property bought with old foreign income, and investments on which business investment relief was claimed, can also be designated.
- Old employment income · foreign earnings from a remittance basis year that are paid on or after 6 April 2025 qualify if received before 6 April 2028.
- Offshore trusts · capital payments received in 2025-26 to 2027-28 can qualify to the extent they are matched to trustee gains from years before 2025-26, per HMRC's trust guidance.
- Income arising after 6 April 2025 · never qualifies, including income treated as arising on return under the temporary non-residence rules.
When the deadlines fall
The designation is made in the Self Assessment return for the tax year concerned. HMRC's time limits guidance allows 12 months beyond the normal filing date:
- 2025-26 · 12 percent · election by 31 January 2028
- 2026-27 · 12 percent · election by 31 January 2029
- 2027-28 · 15 percent · election by 31 January 2030
Two timing rules matter more than the dates. First, a designation is treated as made on 6 April of the tax year, and the exchange rate on that date is used. Second, an amount remitted in a year must be designated in that year's return. HMRC's example of a returning resident states she cannot wait until 2027-28 for money treated as remitted in 2026-27. Outside the amendment window an election cannot be withdrawn, and overpayment relief is not available.
How it interacts with the FIG regime and foreign tax
A former remittance basis user who also qualifies for the four-year FIG regime cannot shelter pre-April 2025 money under FIG. HMRC's guidance on the FIG regime and the TRF states that such amounts must be designated under the facility or taxed at the usual rates when remitted.
Foreign tax is not credited. The charge applies to the amount net of any foreign tax paid or payable, and a full foreign tax credit is only available if the money is remitted as an ordinary remittance instead. Where foreign tax was high, the ordinary route can cost less than the facility, a comparison to raise with your adviser before designating.
Paying the charge itself needs care. HMRC's guidance on the TRF charge notes that paying HMRC from an undesignated offshore account is an ordinary remittance, taxed at normal rates. There is no equivalent of the old exemption for paying the remittance basis charge.
Heed's reading: the rate is fixed by the return year, not by the day money moves, so the 2026-27 return is the last one priced at 12 percent. For anyone who has left the UK, residence in the year of designation decides whether the window exists at all.
Heed monitors international tax law changes across every jurisdiction we track and sends personalised alerts before they affect your situation. Residence counting of the kind that decides TRF eligibility is covered under tax residency tracking.