UK 2025 Non-Dom Reform: CGT Rebasing vs Temporary Repatriation Facility

Why the framing matters

Public commentary often presents UK transitional relief as a single binary "election." That framing obscures the structure. The 2025 reform replaced the remittance basis with a residence-based regime, and HMRC has set out two distinct transitional mechanisms that operate independently.

Anyone advising on this needs to read both side-by-side, not one as an alternative to the other. The accurate orientation:

1. CGT Rebasing, addresses the base cost of personally-held foreign capital assets.
2. Temporary Repatriation Facility (TRF), addresses previously unremitted foreign income and gains accumulated under the old remittance basis.

Specific rates, eligibility conditions, election deadlines and asset categories are set by Finance Act and HMRC guidance. Use the official sources cited below before any election; figures change as guidance is updated.

CGT Rebasing, what it does

CGT Rebasing lets eligible individuals revalue qualifying foreign capital assets to a fixed historical reference date for UK CGT purposes. The effect is that gains accrued before the reference date fall outside the UK CGT computation on a future disposal, only post-reference-date appreciation is taxed.

This matters most for individuals who:

• Held foreign capital assets while a UK resident non-dom,
• Will remain UK tax-resident after 5 April 2025, and
• Plan to dispose of those assets in the medium term.

Rebasing is asset-by-asset. The reference date is 5 April 2017. Conditions include: never UK domiciled or deemed-domiciled before 2025/26; remittance basis claimed in at least one year from 2017/18 to 2024/25; asset owned on 5 April 2017; non-UK situs throughout 6 March 2024 to 5 April 2025; and personally held. Refer to current HMRC guidance for full eligibility rules.

Temporary Repatriation Facility (TRF), what it does

The TRF is a time-limited mechanism allowing accumulated foreign income and gains that arose under the remittance basis (i.e. pre-6 April 2025) to be designated and brought to the UK at a reduced flat rate, without the regular UK income tax or CGT charge that would otherwise apply on remittance.

Key structural features:

• Eligibility, applies to FIG that arose while the individual was taxed on the remittance basis.
• Time-limited, the facility runs for three tax years: 6 April 2025 to 5 April 2028. Designations after the window close at full UK rates.
• Flat rate, 12 per cent for 2025/26 and 2026/27; 15 per cent for 2027/28. No foreign tax credit is available against the TRF charge.
• Use of proceeds, designated funds can be remitted to the UK or invested without further UK charge on the underlying source.

Rates and the closing date for designations are set by Finance Act and updated by HMRC. Always check the live position before designation.

How they interact

CGT Rebasing and the TRF address different layers of the legacy non-dom position:

• Rebasing clears historical CGT exposure on capital assets you continue to hold.
• TRF clears historical income tax / CGT exposure on amounts you previously kept offshore under the remittance basis.

A typical HNWI with both pre-2025 foreign assets and pre-2025 unremitted FIG will engage both, not one. They are complementary, the article framing as an "either/or election" is wrong.

“CGT Rebasing addresses base cost; the TRF addresses accumulated FIG. Treating them as alternatives is the most common framing error we see, they are sequential workstreams, not a binary election.”

What this article does NOT include

We deliberately do not state specific rates, election windows, eligibility cut-offs, or break-even portfolio sizes here. Those are governed by statute and HMRC guidance and are subject to update. Any modelling exercise should:

1. Pull the current rate and election deadline directly from HMRC.
2. Confirm asset eligibility before assuming rebasing applies.
3. Sequence designations and disposals to avoid conflicts between the two mechanisms.

This article describes the structural relationship between two transitional mechanisms; it does not substitute for personalised professional advice.