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RegulatoryUnited Kingdom·Jul 20255 min
TRF: the 12% repatriation opportunity for former UK non-doms
The Temporary Repatriation Facility allows remittance of pre-2025 funds to the UK at 12% (2025/26 and 2026/27) and 15% (2027/28).
By T&C Consulting Group
TRF mechanics
The Temporary Repatriation Facility (TRF) is the three-year window HMRC opened for former non-doms to regularise capital accumulated under the old remittance basis. The rates are fixed and especially competitive versus the 45% marginal:
| Tax year | TRF rate |
|---|---|
| 2025/26 | 12% |
| 2026/27 | 12% |
| 2027/28 | 15% |
What is eligible
- Foreign Income and Gains accrued by 5 April 2025.
- Funds in mixed accounts (may be partially designated).
- Distributions from offshore trusts with pre-2025 income attributable to settlor or beneficiaries.
Strategies
- UK residential property acquisition without triggering legacy remittance charge.
- Capitalisation of UK-controlled companies.
- Settlement of offshore liabilities secured against UK assets.
LatAm considerations
Colombian and Mexican families with two decades on the non-dom regime now face a binary decision: leverage the TRF and consolidate wealth in the UK, or structure an exit toward favourable jurisdictions (Spain's Beckham regime, UAE, Ireland). The analysis must model post-reform IHT, return expectations and FX exposure.