Temporary Repatriation Facility (TRF) – UK Tax Reform

I have already used the 7 years no dom. So how ” the Historic unremitted funds” works for me?

Since you’ve already used the 7 years on the remittance basis, you’re in a very specific position under the new rules, and the Temporary Repatriation Facility (TRF) is exactly designed for people like you.

Time-Limited Opportunity: Unlock the Value of Your Offshore Wealth with the TRF

If you’ve ever claimed the remittance basis as a UK resident non-dom, sweeping tax reforms introduced in Finance Act 2025 are about to reshape your financial landscape — and fast.

From 6 April 2025, the UK is replacing the long-standing remittance basis with a new residence-based tax regime. The changes are significant, but they also come with a unique opportunity: the Temporary Repatriation Facility (TRF) — a two-year window that could transform how you use your offshore wealth.

What is the TRF?

The TRF is a new, one-off tax facility introduced to help former non-doms transition into the new regime. It allows individuals to bring previously untaxed offshore income and gains into the UK — at a flat, preferential tax rate (expected to be 12%).

In short: if you’ve kept funds offshore to avoid triggering a tax charge under the old remittance rules, this is your chance to repatriate them efficiently.


Who Can Benefit?

If you:

  • Have previously used the remittance basis (whether for a few years or many),
  • Hold foreign income or gains in offshore accounts, trusts, or structures,
  • Want to regularise and access those funds in the UK without a punitive tax bill,

…then the TRF may be exactly what you need.

Even if you’ve stopped using the remittance basis, or switched to the arising basis in recent years, your historic unremitted funds are still sitting in the tax danger zone — they become fully taxable if remitted now or in the future, unless you act during this window.


Why Act Now?

  • Lower Tax Rate: Instead of paying up to 45% income tax or 20%+ capital gains tax, TRF offers a flat 12% rate.
  • Simplicity: You don’t need to unravel complex offshore accounts. This is a chance to clean up old structures without years of forensic tracing.
  • Time-Limited: The TRF is only available for two tax years (from April 2025 to April 2027). Once it’s gone, the full UK tax rates will apply.

What Should You Do?

Start with a strategic review:

  1. Identify your offshore accounts — are they clean capital, income, gains, or mixed?
  2. Segregate funds where possible — clean capital can always be remitted tax-free.
  3. Prioritise remittances from accounts with historic income/gains — TRF can shield these from full taxation.
  4. Act early — waiting could cost you flexibility, especially if you need access to these funds in the UK.

How We Can Help

At Cesca Accounting, we specialise in international private client tax planning. We understand the complexities of mixed funds, legacy non-dom structures, and the shifting UK tax landscape. With TRF offering a one-off opportunity, now is the time to:

Repatriate tax-efficiently

Review your position

Reassess your strategy


Simple Decision Tree for You:

The rules have changed — your strategy should too.

Let’s Talk

Our private client team is already advising individuals and families across the UK and abroad on how to take advantage of the TRF before the window closes. Book a consultation today to map out your optimal repatriation plan.

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