The UK’s Temporary Repatriation Facility: A three-year window of opportunity

On 6 April 2025, the UK’s tax code for internationally connected individuals was dramatically overhauled. As a temporary concession to help affected individuals arrange their tax affairs, and (in keeping with its wider policy to discourage the use of offshore trusts for tax planning) to encourage settlors to wind up their non-UK trusts, the UK government has introduced a new Temporary Repatriation Facility (TRF). 

Two of the key changes have been:

1. To abolish the remittance basis of taxation for non-domiciled and non-deemed domiciled individuals.
2. To remove certain protections benefitting offshore trusts, which effectively mean that, for most UK resident settlors of non-UK trusts, those trusts are now “transparent” with income and gains of the trust being immediately taxed on the settlor. 

What is the TRF?

The TRF allows eligible individuals to designate certain historic offshore income and capital gains as “qualifying overseas capital” and pay a flat UK tax charge on those designated amounts at concessionary tax rates.

Qualifying overseas capital is, very broadly, a term used to describe two types of pre-6 April 2025 income and capital gains:

• Non-UK source income and capital gains that arose to an individual personally, but during a year in which they claimed the remittance basis of taxation and so were shielded from UK tax at the time, and which have not subsequently been brought (ie remitted) to the UK and therefore remain untaxed.
• Income and capital gains that arose in a non-UK trust structure, and which would otherwise be “matched” to a capital distribution made in the TRF window at a UK beneficiary’s marginal income tax and capital gains tax rates (up to 45%) under the UK’s complex anti-avoidance regime for trusts. 

The TRF rates are:

• 12% where the designation is made in 2025/26 or 2026/27
• 15% where the designation is made in 2027/28

In other words, the one-time TRF window runs for three tax years (2025/26, 2026/27 and 2027/28). 

Crucially, you don’t have to remit the funds during the three year window to benefit. Once designated, the amounts can be remitted to the UK later without a further UK tax charge on that remittance. It may be beneficial, in some cases, for inheritance tax reasons to keep assets outside the UK post-designation, for example. 

Who can use it?

In broad terms, the TRF is for UK resident individuals who were subject to the remittance basis in at least one tax year before 2025/26, and who either have qualifying amounts to designate personally or who will receive a capital distribution from a non-UK trust before 5 April 2028. 

You can only make a designation election in a self-assessment return for 2025/26, 2026/27 or 2027/28, and you must be UK resident in the year of designation. 

Practical points clients should be doing now:

1. Quantify and evidence your “historic offshore pot”: Identify what part of your offshore wealth is pre 6 April 2025 income/gains that could be taxable if remitted.
2. Consider trust benefits you might receive: If you’re a trust beneficiary (including a settlor who is also a beneficiary), coordinate with trustees about the timing and nature of any capital payments or benefits during 2025/26–2027/28, as this can affect whether TRF is available and at what rate.
3. Factor in foreign tax: TRF is a stand alone tax charge and no foreign tax credit relief is available against the payment (the rules require designation of the amount net of relevant foreign tax where applicable).

Conclusion

TRF is a time limited opportunity to turn pay tax at a flat rate of 12% or 15% on funds that would otherwise be taxed at up to 45% if they were remitted to the UK and/or received from a trust.  

If you have ever claimed the remittance basis of taxation in the past, the TRF might be relevant to you. We would be delighted to advise you in more detail to see if the TRF could help bring down your UK tax bill. 

This article was written for Mills & Reeve's Private Affairs - Summer 2026.

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