# Remittance basis after 6 April 2025 > Legal guide to the abolition of the UK remittance basis, pre-6 April 2025 pools, TRF, mixed funds and transitional rules. Author: Мария Плотникова — юрист, Family Office (https://wiki.private.law/authors/plotnikova) Last modified: 2026-07-14T09:29:00.000Z Canonical: https://wiki.private.law/en/uk-remittance-basis-after-2025 Topics: investments Jurisdictions: uk Product tags: tax-regime, non-dom, wealth-planning Semantic tags: tax-regime, non-dom, wealth-planning --- ## Background: how the basis ended > 🔗 **Related** > [non-dom abolition](https://wiki.private.law/en/uk-non-dom-2025) · [UK tax residence](https://wiki.private.law/en/uk-tax-residence) The remittance basis was a fixture of UK taxation for two centuries. A UK resident who was non-domiciled paid tax on foreign income and gains only when the money reached the country. Finance Act 2008 put a price on the privilege through the remittance basis charge, and Finance (No. 2) Act 2017 layered deemed domicile on top after fifteen of the previous twenty years of residence. Each reform narrowed the regime without retiring it. Jeremy Hunt announced abolition in the March 2024 Budget; Rachel Reeves confirmed and hardened it in the October 2024 Autumn Budget. From 6 April 2025 domicile stopped driving income tax, capital gains tax and, separately, inheritance tax. Residence took its place, measured by the Statutory Residence Test. The full repeal and its replacement sit in the non-dom abolition and UK tax residence entries; this page covers what former remittance-basis users still manage. ## 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. > 🍓 Do not treat the abolition as a clean slate. Pre-6 April 2025 offshore income and gains can still be taxed when remitted unless they are designated under the TRF — and the cheap window closes after 2027/28. Trace each account into clean capital, taxable pools and uncertain pools before moving anything to the UK. ## What survives the abolition > 🔗 **Related** > [family offices](https://wiki.private.law/en/uk-family-office-records) HMRC's [RDRM71000](https://www.gov.uk/hmrc-internal-manuals/residence-domicile-and-remittance-basis/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](https://www.gov.uk/government/publications/remittance-basis-hs264-self-assessment-helpsheet/hs264-remittance-of-pre-6-april-2025-foreign-income-and-gains-and-the-temporary-repatriation-facility-trf) 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 on the FIG regime instead. ## What replaced it: the FIG regime > 🔗 **Related** > [FIG regime](https://wiki.private.law/en/uk-fig-regime) · [overseas workday relief](https://wiki.private.law/en/uk-overseas-workday-relief) New arrivals do not inherit the remittance basis; they get the four-year foreign income and gains regime instead. Someone non-UK resident for the ten consecutive tax years before arriving can claim full relief on foreign income and gains for the first four years of UK residence, even on amounts brought into the country. The mechanics sit in the FIG regime entry. The relief carries a cost. Claiming it for a year forfeits the personal allowance and the capital gains tax annual exempt amount, and it has to be claimed year by year on the return. Employment income earned abroad runs on its own track through Overseas Workday Relief, rebuilt onto the same four-year footing and set out in the overseas workday relief entry. > 💡 FIG is a claim, not a status. A new resident weighs the foreign income and gains sheltered against the allowances surrendered, one tax year at a time, and the four-year clock runs from the first year of UK residence whether or not a claim is made in that year. ## The Temporary Repatriation Facility **Designation charge** HMRC's [RDRM73400](https://www.gov.uk/hmrc-internal-manuals/residence-domicile-and-remittance-basis/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](https://www.gov.uk/hmrc-internal-manuals/trusts-settlements-and-estates-manual/tsem4705) addresses trust income matching, and a distribution funded by protected foreign income may need matching before any remittance conclusion. ## Inheritance tax moved with it > 🔗 **Related** > [domicile and residence in succession](https://wiki.private.law/en/domicile-residence-succession) · [inheritance tax map](https://wiki.private.law/en/inheritance-tax-map) · [trusts and inheritance tax](https://wiki.private.law/en/trusts-inheritance-tax) Inheritance tax changed basis on the same day. From 6 April 2025 worldwide assets fall within the IHT net once a person is a long-term resident, meaning UK resident in at least ten of the previous twenty tax years. Domicile and deemed domicile no longer decide exposure, and the move from the old fifteen-of-twenty rule to a ten-of-twenty test pulls people into worldwide IHT sooner. The domicile and residence in succession and inheritance tax map entries set the wider frame. Leaving does not switch exposure off at once. A long-term resident keeps a tail of IHT on non-UK assets after departure, running from three years up to ten depending on length of residence. Offshore trusts lost their automatic excluded-property shelter: settlor residence now governs whether trust assets stay outside the net, as the trusts and inheritance tax entry explains. > ⚙️ The pivot is years of UK residence, not a label on a form. Someone who never claimed UK domicile can still be a long-term resident for inheritance tax after ten years here, and the remittance history that governed income tax does nothing for the IHT clock. ## 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. ## Where this is heading > 🔗 **Related** > [planning before UK residence](https://wiki.private.law/en/uk-planning-before-residence) · [leaving the UK](https://wiki.private.law/en/uk-leaving) · [HMRC enquiries cleanup](https://wiki.private.law/en/uk-hmrc-enquiries-cleanup) The planning arc now runs off two clocks. The Temporary Repatriation Facility is the cheap window: 12% on designated pre-6 April 2025 foreign income and gains through 2026/27, 15% in 2027/28, then it closes on 5 April 2028 and undesignated amounts revert to ordinary remittance charges. Designation and remittance can fall in different tax years, which makes sequencing the lever. The planning before UK residence and leaving the UK entries handle the entry and exit ends of the same arc. HMRC's primary guidance is public: the [four-year FIG regime guidance](https://www.gov.uk/guidance/check-if-you-can-claim-the-4-year-foreign-income-and-gains-regime) on GOV.UK and the [Temporary Repatriation Facility manual](https://www.gov.uk/hmrc-internal-manuals/residence-domicile-and-remittance-basis/rdrm73400) at RDRM73400. Where records are thin or a remittance position is contested, the HMRC enquiries cleanup entry covers disclosure before designation. > 🍓 Abolition did not erase the old foreign income and gains; it put a meter on moving them. Until 5 April 2028 the meter reads 12% then 15%; after that it reads full remittance rates. The work between now and then is tracing each offshore pool into clean capital, taxable amounts and designation candidates, then designating and remitting in the right order before the window shuts. ## 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. --- ## FAQ ### 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. --- ## Factual claims - Jeremy Hunt announced abolition in the March 2024 Budget; Rachel Reeves confirmed and hardened it in the October 2024 Autumn Budget. - After 6 April 2025 the remittance basis is no longer the live default for new foreign income and gains. - HMRC's RDRM71000 states that from 6 April 2025 it is no longer possible to use the remittance basis of taxation. - The first question is whether the income or gain arose before 6 April 2025 while the individual was within remittance-basis history. - 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. - HMRC's primary guidance is public: the four-year FIG regime guidance on GOV.UK and the Temporary Repatriation Facility manual at RDRM73400.