Temporary Repatriation Facility (TRF) 12% & 15% Tax Rate for Former Non-Doms
Under Finance Act 2025 statutory non-dom transition rules, former remittance basis users can designate unremitted pre-6 April 2025 foreign income and gains (FIG) to pay a reduced flat tax rate of 12% in 2025/26 and 2026/27, rising to 15% in 2027/28. Once designated and taxed, the underlying funds can be remitted to the UK at any time—now or in future years—without any additional UK Income Tax or Capital Gains Tax. This statutory guide breaks down qualifying criteria, the mixed fund relaxation, designation mechanics via Self Assessment (SA109), worked calculations, traps with offshore trusts, and the strict 5 April 2028 facility sunset.
Key Statutory Takeaways
Statutory Rules & Core Thresholds
12% flat rate for designations made in 2025/26 and 2026/27 tax years; 15% flat rate for designations made in 2027/28. Facility strictly closes on 5 April 2028.
In-Depth Legal Framework & Analysis
The UK Government abolished the concept of domicile for tax purposes with effect from 6 April 2025, replacing the remittance basis regime with a residence-based system (the 4-year FIG regime). To manage the transition for long-term UK residents holding unremitted overseas income and capital gains accumulated under the remittance basis, Parliament enacted the Temporary Repatriation Facility (TRF). Without the TRF, remitting those historic overseas funds into the UK would trigger top marginal income tax rates of 45% (or 39.35% for dividends) and capital gains tax of 24%, plus punitive statutory ordering under the mixed fund rules. TRF creates a 3-year statutory bridge allowing former remittance basis claimants to designate and remit these historic pools at an unprecedented 12% (years 1 and 2) or 15% (year 3) flat rate, unlocking capital for UK investment, real estate purchase, business angel funding, or living expenses.
31 January following the end of the tax year of designation (e.g., 31 January 2027 for 2025/26 designations; 31 January 2028 for 2026/27 designations).
Pre-6 April 2025 foreign income and gains remitted outside of TRF designation remain subject to full UK rates: up to 45% for income and up to 24% for capital gains, subject to strict mixed-fund ordering under ITA 2007 s809Q.
Comparing the 4-Year FIG Regime vs. Temporary Repatriation Facility (TRF)
The 4-year FIG regime applies to individuals who become UK tax resident after at least 10 consecutive tax years of non-UK residence. It exempts foreign income and gains arising during the first 4 tax years of UK residence from UK tax, whether remitted or not.
The TRF applies specifically to individuals who were UK tax resident in any tax year prior to 2025/26 and claimed the remittance basis. It applies exclusively to pre-6 April 2025 accumulated foreign income and gains, offering a 12% or 15% flat charge to cleanse historical offshore funds.
A taxpayer who qualifies for the 4-year FIG regime for new post-6 April 2025 income can simultaneously utilise TRF to remit historical pre-2025 funds if they previously claimed the remittance basis during an earlier period of UK residence.
TRF Practical Calculation Examples
Facts: A former non-dom executive living in London has £600,000 in unremitted overseas dividends accumulated in a Jersey brokerage account between 2017 and 2024. Under previous rules, remitting this to the UK to buy a home would have triggered UK dividend tax at 39.35% (£236,100).
Formula: TRF Designation in 2025/26: £600,000 × 12% = £72,000 flat TRF charge.
Outcome: Taxpayer pays £72,000 on their 2025/26 Self Assessment return. The remaining £528,000 can be brought into the UK immediately or in future years with ZERO further UK Income Tax or Capital Gains Tax, saving £164,100 compared to standard remittance rates.
Facts: An Indian entrepreneur has a Singapore bank account with £1,500,000 containing a mix of £500,000 clean capital from pre-UK years, £600,000 pre-2025 foreign trading income, and £400,000 pre-2025 foreign capital gains. Under ITA 2007 s809Q, any withdrawal would be deemed to come from trading income first at 45%.
Formula: Designates £600,000 of income and £400,000 of gains (£1,000,000 total) under TRF in 2026/27: £1,000,000 × 12% = £120,000.
Outcome: The entire £1,500,000 account is now permanently cleansed (£500k original clean capital + £1,000,000 TRF-designated funds). The taxpayer can transfer any portion to the UK without complex forensic tracing or additional tax liability.
Facts: An individual has £2,000,000 of unremitted pre-2025 capital gains in Switzerland. They consider designating in 2026/27 versus waiting until 2027/28.
Formula: 2026/27 Designation at 12%: £2,000,000 × 12% = £240,000. 2027/28 Designation at 15%: £2,000,000 × 15% = £300,000. Post-April 2028 (Facility Closed): Standard CGT at 24% = £480,000.
Outcome: Delaying designation from 2026/27 to 2027/28 increases the tax charge by £60,000. Failing to designate before 5 April 2028 increases the tax bill to £480,000 (an additional £240,000 penalty) upon remittance.
Step-by-Step Statutory TRF Qualification & Execution Framework
Verify that you were UK resident in at least one tax year prior to 2025/26 and formally claimed the remittance basis under Income Tax Act 2007 s809B, s809C, s809D, or s809E on a submitted SA109 return.
Quantify unremitted foreign income and capital gains that accrued strictly before 6 April 2025. Verify that the underlying income or gain arose while you were taxed on the remittance basis.
Under statutory TRF mixed-fund rules, you do not need to separate capital from interest or gains. You specify the exact monetary amount from the account to be designated for TRF treatment.
Complete the TRF section of the Residence, Domicile and Remittance Basis pages (SA109) of your UK Self Assessment tax return for 2025/26, 2026/27, or 2027/28.
Pay the calculated TRF liability through HMRC's standard Self Assessment payment mechanism by 31 January following the end of the relevant tax year.
Once designated and the charge is paid, transfer the designated funds to a UK bank account at any time. Keep bank statements and SA109 confirmation as proof of cleansed funds.
Comprehensive Practical TRF Compliance Workflow
- Request historical bank and brokerage statements for all offshore accounts holding unremitted funds.
- Reconcile income and capital gains accrued strictly up to 5 April 2025 against post-5 April 2025 accruals.
- Segregate any new income or capital gains arising on or after 6 April 2025 into separate clean accounts to prevent contaminating pre-2025 TRF pools.
- Calculate the exact sterling equivalent of foreign currency assets using HMRC official spot rates or monthly exchange averages.
- Ensure sufficient liquid sterling funds are available in the UK or offshore to settle the 12% TRF liability on 31 January.
- Model whether designating 100% of the offshore pool or partial tranche designation aligns best with long-term UK capital requirements.
- Submit the Self Assessment tax return including Box entries on supplementary page SA109 formally electing TRF designation.
- Pay the 12% TRF charge by the statutory 31 January deadline.
- Receive and archive HMRC Self Assessment Statement of Account confirming payment allocation against the TRF charge.
- Instruct offshore bank to transfer designated funds directly to UK receiving bank.
- Provide receiving UK bank's compliance team with a copy of the SA109 return, TRF calculation schedule, and tax payment proof to satisfy anti-money laundering (AML) source of wealth checks.
- Annotate designated balance ledger confirming the funds are now permanent clean UK capital.
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Frequently Asked Questions: Temporary Repatriation Facility (TRF) 12% & 15% Tax Rate for Former Non-Doms
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🏷️ Statutory Temporary Repatriation Facility (TRF) Framework
Provides a temporary 3-year statutory window for individuals previously taxed on the remittance basis to remit historical unremitted foreign income and gains (FIG) accrued prior to 6 April 2025 at preferential flat rates.
Frequently Asked Questions
The Temporary Repatriation Facility (TRF) is a 3-year statutory tax incentive introduced by the UK Government alongside the abolition of the non-dom regime on 6 April 2025. It allows individuals who previously claimed the remittance basis to remit foreign income and gains accrued before 6 April 2025 to the UK at a flat rate of 12% for the 2025/26 and 2026/27 tax years, and 15% for the 2027/28 tax year.
No. Designation is legally separate from remittance. Once you designate an amount on your Self Assessment tax return and pay the 12% or 15% TRF charge, that capital is permanently cleansed. You can remit it to the UK immediately, in pieces over several years, or leave it offshore indefinitely without any further UK tax liability upon subsequent remittance.
Yes. One of the greatest practical advantages of the TRF is statutory mixed-fund relief. Under standard remittance rules (ITA 2007 s809Q), remitting from a mixed account triggers punitive ordering rules where income is remitted first at up to 45%. Under TRF, you can designate a specific amount from the mixed account, pay 12% (or 15%), and remit that amount cleanly without forensic account tracing.
The TRF strictly sunsets on 5 April 2028. Any pre-6 April 2025 foreign income or gains remitted to the UK after 5 April 2028 without a prior TRF designation will be taxed under standard UK tax rules: up to 45% for employment and general income, 39.35% for dividends, and up to 24% for capital gains, subject to full s809Q mixed-fund ordering.
No. Foreign income and capital gains that arise on or after 6 April 2025 cannot be designated under TRF. New income and gains fall under either the 4-year Foreign Income and Gains (FIG) regime (if you qualify as a new resident after 10 years of non-residence) or standard worldwide UK taxation.
You designate funds on the SA109 supplementary pages of your UK Self Assessment tax return for the tax year in which you wish to make the election (2025/26, 2026/27, or 2027/28). The return specifies the designated amount and calculates the corresponding 12% or 15% charge due by 31 January following the end of the tax year.
Common Taxpayer Misconceptions
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