ERSM165250 - International from 6 April 2025: Remittance of chargeable FSI from 6 April 2025
The Finance Act 2025 introduced a new temporary repatriation facility (TRF) as part of a wider set of measures removing the concept of domicile as a relevant connecting factor in the tax system.
From 6 April 2025 it is no longer possible to use the remittance basis of taxation. However, former remittance basis users may have amounts of pre-6 April 2025 foreign income and gains which arose during a period in which they were subject to the remittance basis, which are capable of being remitted and taxed in the future.
The TRF is aimed at encouraging former remittance basis users to remit those pre-6 April 2025 foreign income and gains, and a low tax rate will be available for individuals that choose to use the TRF. The TRF is a temporary measure, available for a fixed period of 3 years: the 25/26, 26/27 & 27/28 tax years.
The TRF rules can also apply to amounts of “Chargeable Foreign Securities Income” that are remitted to the UK in the 25/26, 26/27 & 27/28 tax years, provided the relevant eligibility criteria is met.
Please see RDRM71000 onwards.