Time-limited opportunity for those with comple
x offshore assets to benefit from a favourable tax treatment β but action must be taken early.
The temporary repatriation facility (TRF) is designed to unlock those offshore sources of wealth to boost the UK economy by providing a special reduced rate of tax for qualifying taxpayers for a limited period. It is proposed to allow non-doms to βdesignateβ untaxed foreign funds and pay tax on them at a flat rate β 12% on the value designated between 6 April 2025 and 5 April 2027, and 15% on designations in 2027/28.
π From 6 April 2025, the remittance basis is no longer available. But if youβve built up foreign income or gains before this date, thereβs a window of opportunity:
β
The Temporary Repatriation Facility (TRF)
The TRF allows former remittance basis users to bring foreign income and gains into the UK at a low tax rate. Hereβs what you need to know:
– Applies to pre-6 April 2025 foreign income and gains
– Available for 3 years only: 2025β26, 2026β27, and 2027β28
– Taxpayers designate qualifying overseas capital (even if the funds arenβt remitted during the TRF period) β¦. πΌ βππ£π π‘βππ πππππ¦ ππ£πππ πππ π‘βππ‘ πΌ ππππππ ππππππ π΄ππππ 2025. πΌ π€πππ‘ ππ‘ π‘π ππ π‘ππππ‘ππ π’ππππ π‘βπ ππ πΉ ππ’πππ , ππ£ππ ππ πΌ πππβπ‘ π‘ππππ πππ ππ‘ π‘π π‘βπ ππΎ ππ’π π‘ π¦ππ‘.
– Mixed funds can be included, and priority remittance rules apply
– Foreign tax paid isnβt creditable, but the amount net-of-foreign-tax amounts can be designated
– Overseas assets and past Business Investment Relief (BIR) investments may also qualify
π© If this affects you or your clients, get in touch. We can help review eligibility, prepare designations, and ensure you’re making the most of the TRF window.