Guidance

HS264 Remittance of pre-6 April 2025 foreign income and gains, and the temporary repatriation facility (TRF)

Updated 6 April 2026

If you need to use Making Tax Digital for Income Tax, you should read this helpsheet together with the guidance on how to use Making Tax Digital for Income Tax.

 You will use compatible software to create digital records and send quarterly updates for your self-employment and property income sources. After this, you will make claims and adjustments through the software, instead of the Self Assessment boxes referenced below.

From 6 April 2025, the remittance basis of taxation has been abolished, with the concept of domicile as a relevant connecting factor in the tax system having been replaced by a system based on tax residence. From this date, all UK residents are taxed on the arising basis of assessment on their worldwide income and gains.

This means that the 2024 to 2025 tax year was the last year for which the remittance basis could be claimed, or could apply automatically.

This helpsheet is for former remittance basis users who have unremitted and untaxed foreign income or gains that arose before 6 April 2025. These amounts will continue to be taxed at the usual tax rates if they are remitted to the UK on or after 6 April 2025, unless these amounts are designated under the temporary repatriation facility (TRF).

This helpsheet gives information to help you complete the ‘Foreign’ pages (SA106) and ‘Residence and foreign income and gains (FIG) regime etc’ pages (SA109) of your tax return and must be read together with the relevant notes accompanying each of these pages. It also gives information to help you make a designation under the TRF.

1. The remittance basis

The remittance basis was an alternative tax treatment that was available to individuals who were resident but not domiciled in the UK and had foreign income and gains.

If you were taxable on the remittance basis, you were liable to UK tax in the normal way on your UK source income and gains. But you were only liable to UK tax on any foreign income and gains that you remitted to the UK (see ‘remitted to the UK’).

From 6 April 2025 if you are resident in the UK, you are taxable on the arising basis and pay tax on your worldwide income and gains, subject to the availability of the FIG regime if you are a ‘qualifying new resident’ (see HS266). However, if you have any pre-6 April 2025 foreign income and gains which arose during a period in which you were subject to the remittance basis, they are capable of being remitted and taxed in the future and will need to be declared on your Self Assessment tax return in the year that the remittance occurs, subject to any use of the TRF (see below).

1.1 Remitted to the UK

Commonly foreign income and gains are ‘remitted to the UK’ if they (or something deriving from them) are:

• brought to, or received in, or used in the UK by you or another relevant person
• brought to, or received in, or used in the UK for your benefit or that of another relevant person
• used to pay for a service provided in the UK to you or another relevant person
• used to pay for a service provided in the UK for your benefit or that of another relevant person
• used outside of the UK for a relevant debt in the UK
• used outside the UK to provide a benefit in the UK for a relevant person

A remittance will occur if you remit the actual or original foreign income and gains to the UK or if you remit something that derives from them to the UK.

Example 1

Jules is a former remittance basis user and buys a painting outside of the UK using pre-6 April 2025 foreign income. Jules subsequently brings the painting to his home in the UK. This is a remittance by Jules. The painting derives from or comprises Jules’ foreign income.

Example 2

Jules is a former remittance basis user and buys a villa outside of the UK using pre-6 April 2025 foreign income. Jules subsequently sells the villa and buys a country retreat in the UK using the total proceeds of the sale. This is a remittance by Jules of the foreign income Jules used to buy the villa and of any chargeable capital gain that accrued on the sale of the villa if the disposal was before 6 April 2025 in a year to which the remittance basis applied. If the disposal was on or after 6 April 2025 then the capital gain would be taxed on the arising basis in the year of disposal.

Whilst the monies (apart from the amount relating to the capital gain which is an original gain) brought to the UK to acquire the country retreat are not Jules’ original foreign income, they originate or derive from them.

Most remittances to the UK will be under the primary rules but there are additional rules under which your foreign income and gains may be remitted to the UK. For example, you gift some of your foreign income or gains or something deriving from them to a person other than a relevant person — a gift recipient. It’s still possible for there to be a remittance of your foreign income or gains if the gift is used in such a way that it benefits a relevant person.

Your money or property does not have to be physically imported from overseas for a remittance to occur. For example, it could be money you receive in the UK from another UK resident, in return for money or assets representing your foreign income and gains transferred to them abroad.

RDRM33050 in the Remittance Basis and Domicile Manual (RDRM) gives examples of remittances to the UK, though this list is not exhaustive.

Even where there has been a remittance to the UK you may also need to consider some of the ‘exemptions’ explained in RDRM34000 to determine whether there is any tax liability arising.

1.2 Relevant person

A relevant person is:

• the individual themselves, that’s, the person to whom the foreign income and gains belong
• the individual’s spouse or civil partner, or people living together as if they’re spouses or civil partners
• the individual’s children or grandchildren under 18 years of age (this includes children or grandchildren of their spouse or civil partners)
• trustees of a settlement, if any other category of relevant person is a beneficiary of the settlement
• a close company in which any other category of relevant person is a participator (for example, a shareholder) and its subsidiaries
• a non-resident company in which any other category of relevant person is a participator, and which would be a close company if it were resident in the UK, and its subsidiaries

You can find more information about the remittance basis of taxation and the meaning of terms such as ‘remitted to the UK’ and ‘relevant person’ in the Residence, domicile and the remittance basis: RDR1 guidance.

From 6 April 2012, remittance basis taxpayers who bring their foreign income and gains, or something deriving from those income and gains, to the UK, and invest them in a qualifying target company may claim relief from the UK tax charge that would otherwise arise — this is known as business investment relief. See Remittance Basis: Exemptions: Business Investment Relief for detailed guidance on this.

Although it is no longer possible to use the remittance basis from 6 April 2025, if you are a former remittance basis user you may have pre-6 April 2025 foreign income and gains which you can use to make qualifying investments on or after 6 April 2025.

To claim business investment relief you should complete box 38 of the ‘Residence and foreign income and gains (FIG) regime etc’ (SA109) pages and include a breakdown of the amount invested into each separate company at box 54 ‘Any other information’ box.

You will not be able to make a business investment relief claim after 5 April 2028.

1.3 Deciding what you have remitted

If you make a remittance to the UK from an account containing a single source of income for a single year, for example, employment income, you can easily identify what it is that you have remitted. But if you do not have funds segregated in this way your remittance may be from a mixed fund.

1.4 Remittances from a mixed fund

A mixed fund is a fund of money or other property which contains more than one type of income or capital (including ‘foreign chargeable gains’) or income or capital from more than one tax year. A typical example is a bank account into which different types of income, such as bank interest, dividends and earnings, or capital have been paid.

If you purchase an asset outside the UK, for example a car, the car may also be a mixed fund. That will be the case where money from more than one source or from more than one tax year is used to buy the car.

There are strict statutory ordering rules that you must apply to identify which amounts of income and foreign chargeable gains from within a mixed fund you have remitted.

You can find detailed guidance on the treatment of remittances from mixed funds from RDRM35210 onwards.

2. Completing the ‘Foreign’ pages

2.1 Box 2 Foreign Tax Credit Relief (FTCR)

If you have already paid tax in another country on any amounts of pre-6 April 2025 foreign income that you have remitted to the UK, the rules for allowing credit for foreign tax paid are the same as for any other UK taxpayer unless you make a designation under the TRF. The ‘Foreign notes’, page FN 1, explains the rules.

If you only remit part of a particular amount of foreign income, you can only claim credit for the same part (the proportionate share) of any admissible foreign tax that may have been deducted from that income.

Example 4

Jenny is a former remittance basis user and is liable to UK tax at the rate of 40%. In the 2023 to 2024 tax year, interest of £9,000 was paid into Jenny’s foreign bank account after deduction of tax in the ‘other’ country at the rate of 10% which is available as a credit against UK tax on that income. Jenny decides to remit £4,500 of this interest to the UK. Jenny has not designated any of the interest under the TRF (see below for further guidance on this).

As Jenny has remitted half of the net amount of the interest Jenny was paid, Jenny is able to claim half of the admissible foreign tax as a credit against UK tax on the income. Jenny must pay UK tax as follows:

	Amount
Gross income	£10,000
Foreign tax	£1,000
Net amount	£9,000

	Amount
Remitted amount	£4,500
Available FTCR	£500

Half the income has been remitted and so half the foreign tax is available as a credit against UK tax.

	Amount
Taxable amount	£5,000
UK tax (40%)	£2,000
minus FTCR	£500
Amount to pay	£1,500

If Jenny does not claim FTCR but instead claims a deduction for the foreign tax paid, she is liable to UK tax on the amount remitted of £4,500 × 40% = £1,800.

2.2 Special Withholding Tax

Special Withholding Tax (SWT) is an amount of tax withheld on certain payments to UK residents under the terms of the European Savings Directive and equivalent third party agreements. This tax will be in addition to any foreign tax deducted by the country of origin of the payment. The countries that may deduct SWT are:

• Andorra
• Austria
• Curaçao
• Gibraltar
• Jersey
• Liechtenstein
• Luxembourg
• Monaco
• San Marino
• Saint Maarten
• Switzerland

Where SWT is deducted you’re treated as having paid, in the year of deduction, an equivalent amount of Income Tax in the UK. This can be set against your UK tax liability of that year, or repaid to you if the amount exceeds that liability.

This applies to any tax deducted from foreign income or gains under the UK-Swiss Tax Cooperation Agreement that you opt to have treated as a payment on account. You should make a claim to have the withholding tax treated in this way on your return and you should also supply the certificates provided by your Swiss paying agent to confirm the amounts of withholding tax deducted.

If you do not take this option and HMRC deems the tax paid clears your liability to UK tax in relation to the relevant income or gains, you will not be able to subsequently claim a repayment.

If you previously used the remittance basis, amounts of SWT repaid to you, or set against your Income Tax liability, will be treated as a remittance of income at the time it’s set off or repaid.

Example 5

Grace is a former remittance basis user and received £8,000 in the 2023 to 2024 tax year from a Liechtenstein account after deduction of SWT of £2,000. Grace has not designated any of the interest under the TRF (see below for futher guidance on this).

Grace has not remitted any of the money from the Liechtenstein account but includes an equivalent amount of Income Tax in her return for the SWT to set against other UK tax liability.

Enter on pages F 2 and F 3 of the ‘Foreign’ pages:

	Details
Country or territory code (page F 2 column A)	LIE
Amount of income received (page F 2 column B)	£0
SWT (page F 3 column D)	£2,000

Setting off the SWT against Income Tax liability will mean that part of the interest income is remitted to the UK and will be a taxable amount at that time. Normally the ‘set-off’ will be regarded as having been at 31 January following the tax year.

Grace will therefore have to enter taxable income of £2,500 on her next tax return (remittance £2,000 increased by the rate of SWT (20%) £500; total £2,500). She will not be entitled to any relief for SWT for that year as the full amount has been relieved in this tax year.

If you previously used the remittance basis and you remit part of your foreign income after SWT is deducted, then the amount of your income remitted is calculated by including the appropriate proportion of the SWT.

You’re still able to claim the whole amount of SWT deducted in the year at column D.

Example 6

Adam is a former remittance basis user and received interest in the 2023 to 2024 tax year of £800 from Jersey after deduction of SWT of £200. Adam has not designated any of the interest under the TRF (see below for further guidance on this). Adam remits £400 of the interest to the UK.

	Amount
Interest received in UK	£400
SWT	£100
Total	£500

Enter on pages F 2 and F 3 of the ‘Foreign’ pages:

	Details
Country or territory code (page F 2 column A)	JEY
Amount of income received (page F 2 column B)	£500
SWT (page F 3 column D)	£200

As in example 5, the £200 set-off will be a further remittance at the date it’s set off and subject to the same calculation until the total of the income, £1,000 is taxed. In this example, £250 of income should be included on the tax return of the year when the SWT £200 is set off.

3. Income from overseas sources

All entries on pages F 2 and F 3 must be in UK sterling, not foreign currency. You should convert any foreign currency amounts you ‘remitted to the UK’ to sterling at the rate of exchange that applied on the date of your remittance. If the remitted amount was credited to a sterling bank account you can use the same rate of exchange that was used by your bank.

If you are not sure of the exchange rate to apply, ask your tax adviser or refer to the foreign exchange rates.

3.1 Boxes 7.1 and 7.2 Remitted foreign income excluding dividends

If you previously used the remittance basis, you’re taxable on any remittances of pre-6 April 2025 foreign income (subject to use of the TRF — see below). Do not report remitted property income in the ‘Income from land and property abroad’ section on pages F 4 and F 5. You should include this income, along with other remitted non-dividend income, on pages F 2 and F 3 of the ‘Foreign’ pages (SA106) in the rows headed ‘Remitted foreign income excluding dividends’.

Do not include any amounts of foreign income in this section that you’ve designated under the TRF.

If you have paid any foreign tax and you have not remitted all the income to the UK, you’ll have to apportion the foreign tax accordingly.

Example 7

Richard is a former remittance basis user and received £10,000 in overseas rents in the 2023 to 2024 tax year, on which foreign tax of £2,000 was paid to the overseas tax authority. Richard has not designated any of the income under the TRF.

If Richard remits £6,000 of the income to the UK, the foreign tax attributable to that amount is:

6,000 ÷ 8,000 × 2,000 = £1,500

Richard should enter £7,500 (that is, £6,000 plus £1,500) in column B and £1,500 in column C.

3.2 Boxes 7.3, 7.4 and 7.5 Remitted foreign divided income

If you previously used the remittance basis, you’re taxable on any remittances of pre-6 April 2025 foreign dividends (subject to use of the TRF — see below). You’re liable to UK tax on dividends paid by foreign companies that are remitted to the UK at the normal tax rates and not at the special rates applicable to dividends.

From 6 April 2016 the UK Dividend Tax Credit was replaced by a new tax-free dividend allowance. However, as remitted foreign company dividends are taxable at the normal UK tax rates, the tax-free dividend allowance is not applicable. The dividend nil rate only applies to income that would be charged at the dividend rates of Income Tax.

Do not report remitted dividends in rows headed ‘Dividends from foreign companies. You should include these dividends on pages F 2 and F 3 of the Foreign pages (SA106) in the rows headed ‘Remitted foreign dividend income’. If you have income from more than one country, include separate sheets completing columns A to F and attach to the ‘Foreign’ pages. Add up the figures in column D and put the total in box 7.3. Then, add up the total in column F and put the total in box 7.4.

If a foreign dividend was paid or accrued to a former remittance basis user before 6 April 2016 and qualified for a tax credit in the year it was paid, then there is an entitlement to a tax credit in the tax year the dividend is remitted to the UK. Dividends paid on or after 6 April 2016 do not qualify for a dividend tax credit when the dividend is remitted to the UK. If a dividend does qualify for the credit, you should enter the taxable amount of the qualifying dividend into box 7.5.

Do not include any amounts of foreign dividend income in this section that you’ve designated under the TRF.

4. Temporary repatriation facility (TRF)

The TRF is a temporary measure available from 6 April 2025 for 3 tax years: 2025 to 2026, 2026 to 2027 and 2027 to 2028.

If you’re a former remittance basis user, you can make an election to designate amounts of pre-6 April 2025 foreign income and gains which will then be taxed at a reduced tax rate. For the 2025 to 2026 and 2026 to 2027 tax years that rate is 12%. For the 2027 to 2028 tax year that rate is 15%.

You must make a designation election on the ‘Residence and foreign income and gains (FIG) regime etc’ pages (SA109) of your Self Assessment tax return. You do not have to remit the amount you designate during the TRF period in order to benefit from the low tax rate, although you can choose to. You will not have to report remittances of any amounts that you have designated under the TRF unless you remit them in the same year you designate them.

You can choose the amount of pre-6 April 2025 foreign income and gains that you would like to designate and there is no obligation for you to designate the total of your pre-6 April 2025 income and gains, meaning that partial designations can be made.

Once a designation has been made, the designated qualifying overseas capital will be available for remittance at any time in the future without incurring any further tax charges.

If you designate any amounts held in a mixed fund, the designated qualifying overseas capital, known as ‘TRF capital’, gets remitted in priority to any other amounts in the fund, regardless of the year in which they arose.

Any foreign income and gains that you do not designate under the TRF will be taxed on remittance in accordance with the existing rules set out above. It will be an ordinary remittance of foreign income and gains taxed at the usual tax rates.

4.1 Who can use the TRF

You must:

• be UK resident in the tax year of designation
• have previously used the remittance basis

4.2 What can be designated

You can designate any amounts that are ‘qualifying overseas capital’. This includes:

• pre-6 April 2025 foreign income and gains
• funds of uncertain origin
• capital payments and income from non-UK trusts that are matched to pre-6 April 2025 foreign income or gains within the trust structure
• overseas assets (for example, property, investments)

4.3 How to make a designation

1. Identify qualifying overseas capital 

If you want to make a TRF designation you will need to review your records that relate to foreign income or gains that arose before 6 April 2025.

You may want to consider funds in offshore bank accounts and your offshore assets which derive from amounts of pre-6 April 2025 foreign income and gains. This may include amounts held in joint accounts or jointly held property, or amounts of your pre-6 April 2025 foreign income and gains held by a third party.

You may also want to consider pre-6 April 2025 foreign income and gains that you have invested in ‘exempt property’, or in UK companies on which you’ve claimed business investment relief. You will not need to dispose of your exempt property or remove your business investment relief investments to designate the amount invested.

If you have a mixed fund at 6 April 2025 and it contains amounts which you are not sure are foreign income and gains, you may want to consider these amounts as well.

You may also have received a payment from a non-UK trust during the tax year which is matched to pre-6 April 2025 foreign income or gains within the trust structure. These may be capital payments, or payments of income under the settlements or transfer of assets abroad (ToAA) legislation. 

See RDRM72100 onwards for more information on what ‘qualifying overseas capital’ is.

2. Designate the amount

You must designate the amount on the ‘Residence and foreign income and gains (FIG) regime etc’ pages (SA109) of your Self Assessment tax return.

You should complete:

• box 50 to make the TRF election
• box 51 to quantify the total amount of the designations made (except those relating to capital payments or benefit from trusts)
• box 52 to quantify the amount of designation relating to capital payments and benefits received from trusts
• box 54 to confirm how much of the designated amounts were remitted to the UK in the 2025 to 2026 tax year

All entries must be in UK sterling, not foreign currency.

To convert foreign income into pound sterling, the exchange rate prevailing on the date of designation should be used. As a designation is treated as having taken place at the beginning of the tax year, this is 6 April 2025 for the 2025 to 2026 tax year. 

To convert foreign gains into pound sterling, you should use the exchange rate prevailing at the time the asset is disposed of, not at the time the gain is designated.

If you are unsure as to the source of an amount that you are designating, the exchange rate prevailing on the date of designation should be used. As above, this is 6 April 2025. 

3. Calculating the TRF Charge

You will pay a flat rate tax of 12% on the amounts you have designated for the 2025 to 2026 tax year. This is a charge on capital and is not a tax on income or capital gains.

No foreign tax credit is available against the TRF charge. Any designated qualifying overseas capital will be separate from the rest of your tax calculation and will not form part of your total taxable income or gains. Therefore, a designation will have no impact on your adjusted net income (ANI) calculation or any of your bands and rates.

Any designated qualifying overseas capital will not form part of your net, threshold or adjusted income for pension purposes.

The designation will also not impact your payments on account due for the following year.

4. Keeping records

You must keep your own records of the designated qualifying overseas capital on which the TRF charge has been paid, whether it is within a mixed fund or in an account or asset containing just designated qualifying overseas capital. This should enable you to demonstrate that any remittances are of designated qualifying overseas capital rather than pre-6 April 2025 foreign income or gains on which no designation has been made. 

You will not be required to submit these records to HMRC, unless they are needed as part of a compliance check.

5. Contact

For more information about online forms, phone numbers and addresses contact Self Assessment: general enquiries.