The remittance basis is abolished — and yet "remittance" remains one of the most consequential words in UK private-client tax, because the old regime left a long tail: pre-April 2025 foreign income and gains are still taxable when brought to the UK, under the old remittance rules, unless they are designated under the Temporary Repatriation Facility at its flat rates. With the TRF's cheapest year ending this April and the facility closing entirely in 2028, everyone who ever used the remittance basis has a live, dated decision to make about money that may have sat offshore for decades.
What died, what survives
From 6 April 2025 the remittance basis stopped applying to new income: UK residents (beyond the four-year FIG regime for new arrivals) are taxed on worldwide income and gains as they arise, domicile irrelevant. What survives is the stockpile problem. Every pound of foreign income and gains earned before April 2025 by a remittance-basis user kept its character: remit it now — spend it here, bring it here, use it to settle a UK debt, gift it in ways the rules trace — and it is taxed at today's full rates, exactly as it would have been in 2020. The remittance rules' notorious machinery survives with it: the mixed fund ordering rules that decide which layer of a blended account comes out first (income before gains before clean capital, year by year), the wide definition of remittance that catches credit cards, loans and gifts to close family, and the tracing that follows sold assets into their proceeds. Offshore accounts built in the remittance era remain archaeological sites, and the 2017–19 cleansing window that once let users separate the layers is long closed.
The TRF: a closing window with a price list
The Temporary Repatriation Facility is the exit ramp: designate pre-2025 foreign income and gains in your tax return and pay a flat charge — 12% for designations in 2025/26 and 2026/27, 15% in 2027/28 — after which the designated amounts are cleansed: remit them whenever convenient, this decade or next, with no further tax, and they even take priority out of mixed funds. Set 12% against the alternative — up to 45% on remitted income — and the arithmetic is rarely close for money likely ever to be wanted onshore. Three design points matter: designation does not require remitting (you buy the cleansing now, use it later); the current tax year is the last at 12%; and after April 2028 the facility is gone, leaving un-designated stockpiles taxed at full rates on remittance indefinitely. For anyone with meaningful pre-2025 FIG, this-year designation is among the clearest deadline-driven decisions in current UK tax planning — and it needs the mixed-fund analysis done first, because designating the right layers is where the value is.
The adjacent pieces
Business Investment Relief — the old rule letting remittance-basis money enter the UK untaxed if invested in qualifying companies — remains available for pre-2025 funds, but closes to new claims from April 2028, aligning with the TRF's endpoint; existing investments keep their relief. Overseas Workday Relief was rebuilt rather than abolished: new qualifying residents get up to four years of relief on foreign workdays, now capped annually at the lower of 30% of employment income or £300,000, and — mercifully — without the old offshore-bank-account choreography for post-2025 earnings (legacy OWR money must still stay offshore under the old rules). And the compliance backdrop has hardened around all of it: worldwide account data flows to HMRC automatically, and the nudge-letter machinery works through it — historic remittance positions that were never quite right are better volunteered than discovered.
The order of operations
For former remittance-basis users the sequence this year: reconstruct the offshore picture (accounts, layers, what is income, gain and clean capital — the mixed-fund workings that make or break everything downstream); quantify the designation decision at 12% against realistic onshore needs; sweep for accidental remittances already made (the UK credit card paid offshore, the gift to a UK-resident child); and fold the answer into the wider position — FIG status, the residence tests, and estate planning for funds that will now, cleansed, sit in a UK-taxable estate. Acumon's non-dom and former-remittance specialists run exactly this exercise with our private client team — and the honest framing is that the regime's end made the planning simpler but more urgent: one facility, two rates, one deadline, and a mixed-fund analysis standing between you and the cheap exit.