Remittance Basis and Domicile Manual

RDRM76100 - Temporary repatriation facility: Interaction with other rules and regimes: FIG regime and the TRF

From 6 April 2025, all UK residents are taxed on the arising basis of assessment on their worldwide income and gains. Individuals who come to the UK after a period of at least 10 consecutive years of non-UK residence can claim UK tax relief on foreign income and gains that accrue during their first 4 years of UK residence. This relief for qualifying new residents is known as the FIG regime. See RFIG41000 onwards for guidance on this relief.

Individuals who have been subject to the remittance basis in prior tax years, but are still within their first 4 years of UK residence following a period of 10 years of consecutive non-UK residence, may qualify for both the temporary repatriation facility (TRF) and the FIG regime. It is not possible to claim relief under the FIG regime on any amounts of foreign income and gains that arose prior to 6 April 2025 when an individual was UK resident and subject to the remittance basis. This is the case whether the foreign income and gains are remitted in the first 4 years of the individual returning to the UK or any time after. 

Instead, individuals will need to designate the remitted foreign income and gains under the TRF, provided the funds meet the criteria to be qualifying overseas capital (see RDRM72100), or pay tax on remittance at the usual tax rates.

Example

Wanjiru is UK resident and a former remittance basis user. She came to the UK for the first time on 6 April 2023.

In the 2023-24 tax year she earned £100,000 of foreign income which was paid into an overseas bank account. She was subject to the remittance basis for 2023-24 and did not remit any of the £100,000 to the UK, so was not taxed on this amount.

On 6 April 2025 Wanjiru still has the £100,000 of foreign income from 2023-24 in her overseas bank account. It is no longer possible to use the remittance basis of taxation, but as Wanjiru had 10 years of consecutive non-UK residence prior to 6 April 2023, she will qualify for the FIG regime for the 2025-26 and 2026-27 tax years. 

On 7 April 2025 Wanjiru sells a piece of artwork she has held for many years overseas, making a gain of £50,000. As Wanjiru is eligible, she can claim relief for the £50,000 foreign gain under the FIG regime in 2025-26.

On 1 May 2025 she remits to the UK £75,000 of the foreign income she earned in the 2023-24 tax year.

This remittance of pre-6 April 2025 foreign income will not qualify for relief under the FIG regime. Wanjiru will be taxed on the £75,000 remitted to the UK in 2025-26 at the usual tax rate unless she makes a designation election under the TRF.

Wanjiru is not limited to making a designation election for just the £75,000 that has been remitted to the UK in 2025-26. She could also designate the remaining £25,000 that has not yet been remitted.