Temporary Repatriation Facility (TRF): how it works and what to include in your 2025-26 tax return

What is the Temporary Repatriation Facility (TRF)? A UK tax opportunity for offshore funds

The Temporary Repatriation Facility (TRF) gives some individuals a limited opportunity to bring historic foreign income and gains into the UK at a reduced tax rate.

If you have previously used the remittance basis and still hold funds offshore, the TRF may be relevant. However, it is not automatic. Whether it applies and the tax position will depend on decisions made now and what is included in your tax returns.

Temporary Repatriation Facility (TRF): key rules, rates and eligibility (2025-2028)

The Temporary Repatriation Facility (TRF) allows a person who has previously claimed the remittance basis, who is a UK tax resident, to remit previously accrued foreign income and gains (FIG) to the UK after 5 April 2025 at a reduced rate. The relief is available for three tax years.

To use the TRF, you must ‘designate’ in your tax return the amount of FIG on which you want to pay the TRF charge.

Designations made in 2025-26 and 2026-27 will be taxed at a flat rate of 12%, with the rate rising to 15% for designations made in 2027-28.

Once an amount has been designated and the tax paid, it can be brought to the UK without further UK tax. Taxpayers can, therefore, make designations in respect of amounts they wish to remit in the future. The taxpayer will not need to declare remittances of designated FIG made in subsequent years.

If a remittance does arise in a tax year, the amount must be designated in the same or an earlier tax year to ensure the TRF rates apply.

Temporary Repatriation Facility (TRF): at a glance

Tax rates

• 12% in 2025-26 and 2026-27
• 15% in 2027-28

Who can use it

• Individuals who previously used the remittance basis and are UK resident in the year of claim

Time limit

• Available for three tax years from 6 April 2025 to 5 April 2028

Remittances

• Amounts do not need to be brought to the UK in the same year they are designated

What qualifies for the TRF? Foreign income and gains you can designate

The rules refer to ‘qualifying overseas capital’. In simple terms, this means FIG that:

• Arose before 6 April 2025,
• Were not taxed in the UK because the remittance basis applied, and
• Could otherwise be taxable if brought to the UK.

In practice, this may include:

• Cash held offshore
• Foreign income and gains used to acquire investments or other assets
• Amounts where the original source is uncertain
• Specific offshore trust distributions

You do not have to include everything. Deciding what to designate, and when, will often depend on the nature of the funds and your wider tax position.

How to report TRF in your 2025-26 UK tax return

Why your 2025-26 return is critical for TRF claims

The TRF is claimed through the self-assessment tax return. It does not apply unless an election is made.

For 2025-26 the self-assessment tax return filing deadline is 31 January 2027 (for online returns).

While amendments may be possible until 12 months after the filing deadline, getting the position right in the original return is usually preferable.

TRF on SA109 tax return pages: boxes 50-54 explained

The 2025-26 Residence and foreign income and gains (FIG) regime etc (SA109) pages include specific boxes for TRF claims:

Box 50 – confirms that a TRF election is being made

Box 51 – amounts designated from personal foreign income and gains

Box 52 – amounts designated from trust distributions

Box 53 – amounts designated that have been brought to the UK in the tax year

Additional detail will often be needed to explain how amounts have been calculated.

What does ‘designation’ mean under the TRF? Practical examples

To use the TRF you must designate an amount in your tax return.

In practical terms, this means:

• Identifying an amount of pre-6 April 2025 FIG (or an amount where the source is uncertain and it is to be treated as pre-6 April 2025 FIG), and
• Including that amount in the return in the relevant box or boxes so it is taxed at the reduced rate.

The return must show the total amount designated and, separately, any part of that amount that has already been brought to the UK.

TRF reporting: what to include in ‘any other information’ (Box 54)

The detail included in the “Any other information” box (box 54) is likely to be important to ensure the tax return is correct, compliance obligations are met and to reduce the possibility of an HMRC enquiry.

HMRC guidance indicates that further detail needed here may be:

• Details of funds or accounts being designated
• Explanations of partial designations
• Analysis supporting trust matching
• Confirmation of how remittances relate to designated amounts
• Notification of any TRF capital account

Even where this information is not included in the return, records must be retained to support the position taken.

TRF checklist: key steps before filing your tax return

Identifying historic funds for TRF

The starting point is understanding what funds exist and where they came from.

This may involve:

• Reviewing offshore bank accounts
• Tracing movements over time
• Distinguishing income, gains and capital
• Reconstructing records where these are incomplete

This can take time, particularly where funds have been held for many years.

Mixed funds and TRF

Mixed funds are common and remain an area where care is needed.

The TRF introduces some helpful rules, such that amounts which are designated are treated as being remitted before other amounts, but detailed analysis may still be required. In some cases, it may also be worth considering whether to use a separate TRF capital account to track designated funds more clearly.

TRF exchange rates

The TRF uses exchange rates at the start of the tax year, rather than the date funds are brought to the UK.

How to pay TRF tax without triggering a taxable remittance

Care is also needed when paying the TRF charge. Using un-designated foreign income or gains to pay the tax can itself create a taxable remittance. Planning how the tax will be funded should therefore be part of the initial analysis.

TRF and offshore trusts

The TRF applies to individuals, but it can also be relevant where offshore trusts are involved.

Distributions received during the TRF period may, in some cases, be matched to pre‑6 April 2025 income or gains and be brought within the TRF.

Why TRF is more complex for offshore trusts

For offshore trust structures, additional issues arise, including:

• Whether the beneficiary qualifies
• How distributions are matched to underlying income or gains
• Whether more than one designation may be required
• Whether a separate calculation is needed for TRF purposes

Timing may also be important. The timing of distributions can affect whether the TRF is available and the rate that applies.

TRF compliance checklist: step-by-step guide for 2025-26

1. Identify relevant funds
2. Analyse what qualifies for the TRF
3. Decide what to designate
4. Plan how the tax will be paid
5. Complete the tax return
6. Keep records

Temporary Repatriation Facility (TRF): why you should take advice now

The TRF runs until April 2028, but decisions for 2025-26 need to be considered ahead of the filing deadlines.

For many individuals, this is a one-off opportunity and may form part of a broader review of historic transactions and future plans.

How Saffery’s international private client team can help with TRF

Many of our clients have international tax issues. They may be arriving in or leaving the UK, may have previously used the remittance basis, or may hold overseas investments, businesses or trust interests.

We can help with:

• Identifying which funds qualify for the TRF
• Reviewing offshore accounts and mixed funds
• Advising on what to designate and when
• Considering the position for offshore trusts
• Preparing tax returns, including the Residence and foreign income and gains (FIG) regime etc (SA109) pages
• Managing HMRC compliance risk

We also advise internationally mobile individuals on wider structuring and planning, including steps that may be worth considering before arriving in or leaving the UK.

Where appropriate, we work with overseas advisers to ensure cross‑border issues are properly managed.

If you would like to discuss the Temporary Repatriation Facility (TRF), please speak to your usual Saffery contact or get in touch with Alexandra Britton-Davis.