Temporary Repatriation Facility: What you need to know

3 July 2026 • Warrener Stewart

On 6 April 2025, changes to the UK’s residency rules came into force, reshaping how internationally mobile individuals are taxed when arriving in – or leaving – the UK. Among these changes is a measure that has attracted attention: the Temporary Repatriation Facility (TRF).

The TRF is designed for individuals who have previously claimed the remittance basis in any tax year up to and including 2024/25. In simple terms, it offers a window to bring historic foreign income and gains into the UK at potentially a significantly reduced tax rate.

For many long‑term UK residents – especially entrepreneurs, senior executives and internationally active investors – this represents a rare opportunity.

What the TRF allows you to do

Under the old rules, foreign income and gains that were kept offshore could trigger a full UK tax charge if remitted later. The TRF changes that position for a limited period.

For three tax years, designated remittances will be taxed at:

• 12% in 2025/26
• 12% in 2026/27
• 15% in 2027/28

Compared to standard income tax and capital gains tax rates, this is a material reduction.

The government’s intention is clear: to encourage former non‑doms to bring historic funds into the UK economy, rather than leaving them offshore indefinitely.

Who is likely to benefit?

The TRF will be particularly relevant for individuals who:

• Have accumulated foreign income or gains over several years
• Now expect to remain UK‑resident for the long-term
• Require access to offshore funds for investment, property purchases or business activity
• Want to simplify their affairs and reduce ongoing administrative complexity

For many, the facility offers a way to unlock offshore wealth at a lower tax cost, while also reducing the burden of maintaining complex remittance records.

Why timing matters

The TRF is only available for three years, and the tax rate increases in the final year. For individuals considering a remittance, the question is not simply whether to use the facility, but when.

Used correctly, the TRF can:

• Reduce tax exposure
• Simplify long‑term financial planning
• Remove historic remittance traps
• Support UK‑based investment or business growth

However, the rules are detailed, and careful planning is essential to ensure the remittance qualifies for the reduced rate.

A rare opportunity but not a simple one

Although the TRF is generous, it is not automatic. Decisions around designation, timing, source tracing and interaction with other residency changes must be handled carefully.

For business owners and high‑earning individuals, the facility may form part of a wider review of UK residency, investment strategy and long‑term tax planning.

How Warrener Stewart can help

Our private client team advises many internationally mobile individuals, entrepreneurs and senior executives on residency, remittances and worldwide tax planning. If you think the Temporary Repatriation Facility may apply to you — or you simply want to understand your options — we can help you assess the potential benefits and structure a compliant, efficient approach.

To discuss your position, please contact your usual Warrener Stewart representative, or email info@warrenerstewart.com.