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Foreign Income and Gains - what is the temporary repatriation facility (TRF) ?

The temporary repatriation facility (TRF) was introduced in the Finance Act 2025 to replace the remittance basis for UK non-domiciled residents and remove domicile as a tax factor, allowing eligible UK-resident individuals to designate pre-6 April 2025 foreign income and gains (FIG) and pay a reduced tax rate rather than standard rates.

TRF is available for a fixed three-year period: 2025–26, 2026–27, and 2027–28. The tax rates under TRF are 12% for 2025/26 and 2026/27, and 15% for 2027/28 tax years.

Key Factors for claiming TRF

  • Only former remittance basis users who are UK-resident during the relevant year and have qualifying overseas capital (QOC) may use the facility.
  • Designation of funds can include cash, investments, property, or trust distributions, even from mixed or jointly held accounts.
  • Designation does not require immediate remittance; once designated and taxed at the TRF rate, further UK tax does not apply upon remittance.
  • Funds designated under TRF are given priority in remittance order over other overseas funds, simplifying account management.
  • No credit for foreign tax paid is available against the TRF charge, and the facility operates separately from standard income tax, capital gains tax, and inheritance tax computations.
  • TRF encourages voluntary disclosure and repatriation of untaxed historic offshore income and gains, offering a simplified, lower-rate taxation window before future remittances may face normal rates up to 45%.

How to enter TRF income and gains in TaxCalc

SimpleStep >Navigate to Residence and Foreign Income and Gains (FIG) Regime >Temporary Repatriation Facility (TRF)

HMRC Forms mode > Navigate to Residence and Foreign Income and Gains (FIG) Regime > Page 3 > Boxes 50 to 53

More information can be found on TRF in HMRC Manual 71000
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