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The TRF ― an overview

Though the remittance basis is abolished for 2025/26 onwards, foreign income and gains which arose before this date when the taxpayer was a remittance basis user will continue to be taxed as they are remitted to the UK. The temporary repatriation facility (TRF) is a time limited opportunity for previous users of the remittance basis to ‘designate’ amounts of unremitted overseas capital (known as qualifying overseas capital, or QOC) on which to pay a flat rate of tax with no further UK tax liability when it is then remitted to the UK. The opportunity is available for 2025/26, 2026/27 and 2027/28 at a rate of 12% for 2025/26 and 2026/27 and 15% for 2027/28. This is essentially a transitional relief from the remittance basis that applied for 2024/25 and previous years.

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