Temporary Repatriation Facility (TRF) – Autumn Budget 2024

When the previous government announced the changes to the ‘non-dom’ regime in Spring, it was felt the TRF opportunity was one that a likely incoming government would not support. However, now that we have seen their Budget, they have in fact kept this opportunity and indeed, extended it by a tax year.

From 6 April 2025, taxpayers who have previously made a claim to be taxed on the remittance basis and have funds outside the UK, which would be subject to large tax liabilities if they are remitted, can now do so, knowing what rate of tax would be charged.

The facility will be available for three years, covering 2025/26, 2026/27 and 2027/28 tax years. For the first two tax years, the rate of tax will be 12% and for the third it will be 15%.

It has been announced the tax charge will be on designation of the remittance, and not when the remittance is made. The designation can therefore be made during the relevant tax year and then the remittance can be made later.

During the Budget two major announcements were made to the charge. The first is that any overseas tax paid on the amounts designated will not be offset against the charge, and neither can any remittance basis charges they have paid.

The TRF will provide a welcome opportunity to long-term UK tax residents who have not been able to remit funds to the UK for investment for fear of large tax liabilities. These three years provides those individuals who will reside in the UK for the long term, such an opportunity.

If the Autumn Budget has raised any questions for you, book your place on our question time webinar this Friday at 9:30am. Alternatively, if you would like any further information or guidance on this topic, get in touch with your usual Kreston Reeves contact or contact us here.