United Kingdom · Tax regime
Temporary Repatriation Facility
A hard three-year window: 2025/26, 2026/27 and 2027/28. It closes permanently on 5 April 2028 and the rate does not rise beyond 15% — it simply ceases to exist, after which the ordinary remittance rules of up to 45% return.
This is the cheapest exit any long-standing UK non-dom will ever be offered on decades of trapped offshore income and gains — a one-time amnesty priced at roughly a quarter of the ordinary remittance charge. Once designated and taxed, the funds can be brought onshore and spent with no further UK tax, and the historic mixed-fund tracing problem disappears with them.
The facts
- Total landed cost
- 12% of designated capital for amounts designated in 2025/26 or 2026/27; 15% for amounts designated in 2027/28. On GBP 10m of unremitted historic FIG that is GBP 1.2m now versus up to GBP 4.5m on an ordinary remittance later
- Physical presence
- n/a — but you must be UK resident in the year of designation
- Family
- individual only; each former remittance basis user designates their own qualifying overseas capital
- Permanent residency
- n/a
- Citizenship
- n/a
- Dual citizenship
- Permitted
- Requirements
- previously taxed on the remittance basis (by claim or automatically)hold qualifying overseas capital representing pre-6 April 2025 foreign income and gainsUK resident in the tax year of designationdesignate the amount on the Self Assessment return for 2025/26, 2026/27 or 2027/28
- The deadline is the product. Designation must happen by 5 April 2028 and there is no evidence of any intention to extend it; the 12% rate specifically dies on 5 April 2027.
- You must have actually paid tax on the remittance basis previously, whether by claim or automatically. Individuals who assumed they were remittance basis users but never were do not qualify.
- Designation is irrevocable and the tax is due whether or not you ever remit the money. Designating capital you will never bring onshore is a pure cash loss.
- Identifying and quantifying 'qualifying overseas capital' inside decades-old mixed funds is expensive forensic work. Firms are quoting six-figure fees on complex estates, and the analysis takes months — starting in 2027 may be too late.
- Interaction with offshore trusts is intricate and was the subject of technical amendments in Finance Bill 2025-26. Trust-held FIG needs specialist advice, not a spreadsheet.