22nd July 2025

Head of Tax, Peter Webb, explores how the UK’s new Temporary Repatriation Facility (TRF) offers non-UK domiciliaries a rare opportunity to bring previously untaxed overseas income and gains into the UK at a much lower rate of tax.

What Is the Temporary Repatriation Facility?

The Temporary Repatriation Facility (TRF) is a time-limited tax opportunity introduced as part of the UK’s overhaul of the non-domicile (non-dom) regime.

It allows non-UK domiciled individuals who have previously claimed the remittance basis of taxation to bring their unremitted overseas income and gains into the UK and pay a flat tax rate of 12% – significantly lower than the standard income tax and capital gains tax rates of up to 45%.

This facility provides a valuable window for affected individuals to simplify their tax affairs and make use of overseas funds that have been sitting outside the UK.

How Long Is the TRF Available?

The TRF is available for a limited period:

• Tax year 2025/26: flat 12% rate
• Tax year 2026/27: flat 12% rate
• Tax year 2027/28: flat 15% rate

After 5 April 2028, the Temporary Repatriation Facility closes. Any overseas income or gains that remain outside the UK beyond that date will lose access to the preferential tax rate.

Funds brought into the UK after the TRF window closes could be taxed at rates of up to 45% – more than three times higher.

Who Can Benefit from the TRF?

The TRF is designed for:

• Individuals who have previously been non-UK domiciled, and
• Have claimed the remittance basis to exclude unremitted foreign income and gains from UK tax.

If you meet these criteria, this facility could provide a one-off opportunity to bring capital into the UK on favourable terms.

What Funds Are Covered?

The TRF applies to:

• Overseas income and gains that were excluded from UK tax under a remittance basis claim.

It does not apply to:

• Clean capital (already taxed or originally non-taxable funds)
• Newly arising income or gains generated after 6 April 2025

Each case must be carefully reviewed to ensure correct classification before any remittance is made.

Why This Matters for UK Tax Planning

This is not just a technical change – it’s a strategic tax planning opportunity.

For years, many non-doms have maintained offshore accounts containing untaxed income and gains. The TRF offers a chance to restructure and repatriate wealth before the UK’s wider non-dom reforms take full effect.

By using the TRF wisely, individuals can:

• Bring funds into the UK for investment or spending at reduced tax cost
• Simplify complex offshore arrangements
• Reduce exposure to future policy risk or anti-avoidance measures

However, the timing is critical. Decisions made after the TRF window closes could result in significantly higher tax liabilities.

How Metis Can Help

At Metis, our tax team specialises in UK tax planning for internationally mobile clients.

We can help you:

• Determine if you qualify for the Temporary Repatriation Facility
• Calculate potential liabilities and benefits under the 12% or 15% rates
• Reorganise offshore structures efficiently and compliantly
• Develop a succession and estate planning strategy that complements the UK’s evolving non-dom rules

  This is wealth. Built with Wisdom.

  If you’d like to discuss UK tax, wealth management, or succession planning, our advisers are here to help
  

  Please note this is a general guide and is not advice that can be relied on. It is important that you seek specific advice for your own circumstances. 

  This material is intended for both Professional and Retail Clients, as defined by the Dubai Financial Services Authority. Metis Financial Planning Limited is regulated by the Dubai Financial Services Authority.