Concept
After 6 April 2025 the remittance basis is no longer the live default for new foreign income and gains. Its remaining role is transitional: identifying pre-6 April 2025 foreign income and gains, mixed funds, clean capital, prior remittance-basis claims and the Temporary Repatriation Facility.
This is general legal information, not individual tax advice. UK residence, treaty position, trust attribution, company residence and IHT exposure turn on facts and documents.
What survives the abolition
HMRC's RDRM71000 states that from 6 April 2025 it is no longer possible to use the remittance basis of taxation. Former remittance-basis users may still hold pre-6 April 2025 foreign income and gains that can be remitted and taxed unless designated under the TRF. HS264 sets out the Self Assessment treatment of pre-6 April 2025 remittances and of TRF designations.
This is for former remittance-basis users, trustees, family offices and clients with mixed offshore accounts, historical foreign income and gains, business investment relief history or trust benefit pools. A new resident with only post-6 April 2025 foreign income and gains starts with the FIG regime instead.
The Temporary Repatriation Facility
Designation charge
HMRC's RDRM73400 sets the TRF charge at 12% for designations in the 2025/26 and 2026/27 tax years and 15% for 2027/28. It is a charge on capital, not income tax or CGT.
What it covers
Designation applies to qualifying pre-6 April 2025 foreign income and gains, including certain pre-2025 amounts in offshore trusts attributable to the settlor. The designated amount must be identifiable in the offshore source.
The window
The facility is time-limited. After 5 April 2028 it closes and undesignated pre-6 April 2025 foreign income and gains fall back to ordinary remittance charges with no preferential rate.
The tracing test
The first question is whether the income or gain arose before 6 April 2025 while the individual was within remittance-basis history. The second is whether the account, asset or benefit represents qualifying overseas capital. The third is whether a TRF designation is available, valid and economically rational. Undesignated pre-6 April 2025 foreign income and gains can remain exposed to ordinary remittance charges if remitted.
Mixed funds and trusts
A former remittance-basis user with a mixed Swiss account containing 2022 foreign dividends, 2023 gains and clean capital cannot treat the whole account as clean merely because the remittance basis has ended. Mixed-fund ordering rules decide what is treated as remitted first. Former non-doms with offshore trusts have a separate settlements analysis: HMRC's TSEM4705 addresses trust income matching, and a distribution funded by protected foreign income may need matching before any remittance conclusion.
Common mistakes
- Assuming the regime is irrelevant after abolition and remitting freely.
- Treating all offshore capital as clean capital without tracing.
- Paying the TRF charge from undesignated foreign income rather than clean funds.
- Losing the historical bank statements and remittance-basis returns needed to prove clean capital.
- Ignoring indirect remittances and trust-matching rules.
Evidence
Evidence includes historic remittance-basis returns, account statements, source-of-funds schedules, clean-capital computations, mixed-fund tracing, prior remittance-basis charge history, business investment relief documents, trust distribution records and TRF designation calculations.
Advisor trigger
A chartered tax adviser can handle clean-capital tracing and TRF modelling where records are complete. A UK tax solicitor should be involved where there are trusts, business investment relief history, missing records, prior non-disclosure or a contested clean-capital position.
Q&A
Can a former non-dom still use the remittance basis for new income
No. For new post-6 April 2025 foreign income and gains, the remittance basis is not the current default regime. The arising basis applies, subject to the FIG regime for qualifying new residents.
Is the TRF available to everyone
No. The TRF is for former remittance-basis users with qualifying pre-6 April 2025 overseas capital. It requires an eligible designation and identifiable amounts in the offshore source.
Is the TRF charge a foreign tax credit claim
No. HMRC treats the TRF charge as a charge on capital with its own designation mechanics — 12% for 2025/26 and 2026/27, then 15% for 2027/28 — not an income tax or CGT computation.
Can old offshore funds simply be moved to the UK now
Only after tracing. A mixed account may contain untaxed foreign income or gains that are taxed on remittance unless designated under the TRF.
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