Singapore VCC insights

Temporary Repatriation Facility Before a Move to Singapore: Designating Pre-2025 Foreign Income and Gains

By VCC Editorial Team · Published 9 November 2026

Short answer: A former remittance basis user can designate pre-6 April 2025 foreign income and gains under the UK temporary repatriation facility at 12% for 2025-26 and 2026-27, or 15% for 2027-28, but only in a tax year in which they are UK resident. A principal moving to Singapore should therefore designate before the first fully non-resident year.

This article is general information only and is not legal, tax or investment advice. For matters needing legal advice, we work with a panel of experienced Singapore law firms.

For a principal who used the UK remittance basis and is now planning a move to Singapore, the temporary repatriation facility (TRF) is a decision with a closing date. It sets a flat rate on old offshore money, but only while the individual is still UK resident, and the last window shuts with the 2027-28 tax year. This guide covers eligibility, scope, trust distributions and the timing of departure. UK statements are taken only from GOV.UK and legislation.gov.uk, and Singapore statements only from the Inland Revenue Authority of Singapore (IRAS). All sources were checked on 9 November 2026.

What is the temporary repatriation facility, and who can use it?

It is a three-year election letting former remittance basis users pay a flat charge on pre-6 April 2025 foreign income and gains (FIG), which can then be brought to the UK without further income tax or capital gains tax (CGT). It needs a past remittance basis year and UK residence in the year of designation.

The remittance basis ended on 5 April 2025. HMRC’s Remittance Basis and Domicile Manual (RDRM71000) describes the facility as “available for a fixed period of 3 years: the 2025-26, 2026-27 and 2027-28 tax years”. Paragraph 1(5) of Schedule 10 to the Finance Act 2025 limits designation to an individual who “was subject to the remittance basis for at least one tax year”. That includes a year in which the remittance basis applied automatically without a claim.

The residence condition is the one that matters to a leaver. Paragraph 1(7) allows a designation election only if the individual is UK resident for the tax year of the return under the statutory residence test (SRT) in Schedule 45 to the Finance Act 2013. HMRC states at RDRM73200: “If an individual is non-UK resident under the SRT for a tax year they are not eligible to make a designation election in that tax year.” No one else can designate on their behalf.

What can be designated under the temporary repatriation facility?

Anything that is “qualifying overseas capital”: pre-6 April 2025 FIG from remittance basis years, assets bought with it, funds of uncertain origin, and certain trust payments matched to pre-2025 income or gains. Income and gains arising from 6 April 2025 cannot be designated.

HMRC’s helpsheet HS264 lists the categories: 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”; and overseas assets such as property and investments. Partial designation is allowed, and nothing has to be brought to the UK during the facility period. The amount is converted to sterling at the 6 April rate for the year of designation (RDRM73310), and no foreign tax credit is available against the charge.

Two points catch experienced families. Income later earned by investing designated capital is taxed in the normal way (RDRM73600). And if the TRF charge is paid from an undesignated offshore account, the payment to HMRC is itself an ordinary remittance (RDRM73400). Pay from designated or clean capital.

How do mixed funds work once an amount is designated?

Designated amounts, called “TRF capital”, come out of a mixed fund first. That reverses the usual ordering, under which later years’ income was treated as remitted before earlier years’ and capital came last.

HMRC’s guidance at RDRM75100 explains three changes. TRF capital is remitted “in priority to all other kinds of income and gains in a mixed fund”. It can be separated into a special overseas account so that offshore spending does not use it up. And during the facility period an annualised basis replaces the transaction-by-transaction analysis. Segregating TRF capital before departure keeps the records simple.

Can trust distributions be designated under the temporary repatriation facility?

Yes, within limits. A capital payment from a non-UK trust received in 2025-26, 2026-27 or 2027-28 can be designated to the extent it is matched to trustees’ gains of tax years before 2025-26, but only by a beneficiary who is UK resident and eligible in the year of the payment.

The Budget 2026 rates annex, published on 28 October 2026, states that “former remittance basis users can also use the TRF to designate distributions from trust structures, which are matched to foreign income and gains which arose prior to April 2025”. This is existing law in Schedule 10, not a new Budget proposal. HMRC’s guidance at RDRM72400 describes a parallel matching exercise run “for TRF purposes only”: trust gains of 2025-26 onwards are treated as nil, and payments to beneficiaries who are “not UK resident in that year” are ignored. The designated amount then reduces the gain that section 87 of the Taxation of Chargeable Gains Act 1992 would otherwise attribute to the beneficiary.

A settlor-beneficiary may need two designations. In HMRC’s example at RDRM73600, designating £1m of matched trust gains on a distributed painting did not clean the £10m of pre-2025 dividend income used to buy it; both had to be designated. The point for a leaver is timing: a distribution received after the beneficiary becomes non-UK resident cannot be designated by that beneficiary in that year. Our note on what UK Budget 2026 changes for a family trust run from Singapore covers the Budget’s trust measures, which do not alter the facility.

What does the timeline look like, tax year by tax year?

There are three designation years. A leaver can use a year only if it is a UK resident year, including a split year.

UK tax year	TRF rate	Latest date for designation election	Principal who has left for Singapore	Singapore position on the same money
2025-26 (6 April 2025 to 5 April 2026)	12%	31 January 2028	Available if UK resident for 2025-26	Foreign-sourced income received by a resident individual exempt, unless through a Singapore partnership
2026-27	12%	31 January 2029	Available if 2026-27 is a UK resident year, including a split departure year	As above; residence follows the IRAS tests
2027-28	15%	31 January 2030	Not available if non-UK resident for the whole of 2027-28	As above
2028-29 onwards	None	Facility closed	Undesignated pre-2025 FIG taxed at the usual rates if later remitted to the UK while UK resident	Gains on personal investments generally not taxed

The deadlines come from RDRM73320: the anniversary of 31 January after the end of the relevant year. On split years, HMRC’s Residence and FIG Regime Manual (RFIG21020) states that an individual “must be UK resident for a tax year under the SRT to meet the criteria for split year treatment”. A split departure year is therefore a UK resident year for the purpose of paragraph 1(7); confirm the position on your own facts with your UK adviser.

Should a principal designate before or after leaving the UK?

Before, in substance. The election must sit in the return for a tax year in which the principal is UK resident, so the last usable year is normally the departure year. The return itself can be filed after arrival in Singapore, provided it is for that UK resident year and within the deadline.

A principal leaving during 2026-27 can designate in the 2026-27 return at 12%, filed as late as 31 January 2029. One who stays until after 5 April 2028 also has a 15% option for 2027-28; one who is non-UK resident for all of 2027-28 has no third year. An election cannot be withdrawn once the amendment window has passed, and overpayment relief is unavailable because the charge is a charge on capital (RDRM73320). Designate only what may realistically come to the UK.

Planning for a possible return belongs in the departure year too. HMRC’s guidance on temporary non-residence and the TRF (RDRM76200) states that “individuals who are temporarily non-resident cannot make a designation election until their year of return”, and that FIG arising while abroad and taxed on return under the temporary non-residence rules cannot be designated. Pre-2025 relevant foreign income remitted while temporarily non-resident is treated as remitted in the year of return, and can be designated only if that year still falls within the facility. Our refreshed guide for the UK non-dom moving to Singapore covers the temporary non-residence conditions, the inheritance tax tail and the absence of a UK exit tax.

Does the 4-year FIG regime help with pre-2025 money on a later return?

No. The FIG regime for new UK residents relieves FIG arising in the first 4 years of UK residence after at least 10 consecutive years of non-residence, but it never covers income and gains that arose before 6 April 2025 under the remittance basis.

HMRC is explicit at RDRM76100: “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.” A principal returning from Singapore in the late 2030s would find undesignated pre-2025 FIG still taxable on remittance, which argues for designating funds that might one day pay for a UK home or school fees.

How does Singapore treat the same money once the principal is resident?

Singapore does not tax the transfer, so the designation decision turns on future UK exposure, not on anything Singapore charges.

IRAS’s e-Tax Guide Tax Exemption for Foreign-Sourced Income (Fifth Edition), published on 30 January 2026, states that from 1 January 2004 “all foreign-sourced income received in Singapore by resident individuals, except those received through a Singapore partnership, will be exempt from tax where the Comptroller is satisfied that the exemption will be beneficial to them”, under section 13(7A)(b) of the Income Tax Act 1947. Income from a trade or business carried on in Singapore remains taxable. IRAS treats gains on shares, financial instruments and property as generally not taxable for individuals who are not trading. A foreigner is generally tax resident after staying or working in Singapore for at least 183 days in the previous calendar year; see our note on Singapore tax residence for family office principals.

Two consequences follow. Money that will never return to the UK may not need designating, because HS264’s list of remittances turns on money brought to, received or used in the UK, or used abroad for a UK debt or a benefit in the UK; a transfer to Singapore is not on its face within it. And HMRC notes at RDRM73400 that a double taxation convention covering only taxes on income and capital gains does not reach the TRF charge; with no Singapore tax on the same receipt, there is nothing to credit either way. Immigration is a separate step: our sister practice Singapore Employment Agency handles passes for principals and family office staff.

What is the decision sequence for a principal leaving the UK for Singapore?

Work backwards from the departure date, with UK tax advice on the family’s own records at each step.

1. Confirm eligibility: identify at least one tax year before 2025-26 in which the remittance basis applied, whether claimed or automatic.
2. Map qualifying overseas capital: offshore accounts, assets bought with pre-2025 FIG, business investment relief holdings, funds of uncertain origin and trust structures.
3. Fix the departure year under the SRT, including whether split year treatment applies, and so identify the last UK resident year in which a designation can be made.
4. Decide what may ever come to the UK, such as a London property, school fees or a possible return, and size the designation to that, accepting that it cannot be withdrawn later.
5. Time trust capital payments so they are received in a UK resident TRF year, and check whether a second designation is needed where the trust asset came from the settlor’s own pre-2025 FIG.
6. Pay the 12% or 15% charge from designated or clean capital, never from undesignated offshore funds.
7. Segregate TRF capital into its own overseas account and keep records for any HMRC compliance check.
8. File the designation on the SA109 pages by the deadline for that year, then set up Singapore banking and any holding company, such as a Singapore family investment company, with undesignated funds kept separate.

Frequently asked questions

Can I designate under the TRF after I have become non-UK resident?

Not for a non-resident year. Paragraph 1(7) of Schedule 10 requires UK residence for the tax year of the return. You can still file the return for your last UK resident year, including a split year, after you have moved, as long as you meet the deadline for that year.

Did Budget 2026 extend or change the temporary repatriation facility?

As at 9 November 2026, no. The Budget 2026 overview of tax legislation and rates (28 October 2026, updated 5 November 2026) restates the 12% and 15% rates and lists no TRF measure. The trust distribution rules already sit in Schedule 10, as amended by Finance Act 2026.

Do I have to bring designated money to the UK?

No. HS264 confirms you do not have to remit designated amounts during the facility period; once designated, they can be remitted at any later time without further income tax or CGT.

What happens to pre-2025 FIG I do not designate?

It stays under the old rules: if it is remitted to the UK while you are UK resident, it is taxed at the usual rates. HMRC confirms the FIG regime cannot relieve it, even after 10 years away.

Sources

• Finance Act 2025, Schedule 10, paragraph 1 (legislation.gov.uk)
• HMRC Remittance Basis and Domicile Manual: temporary repatriation facility (RDRM70000)
• HMRC helpsheet HS264: remittance of pre-6 April 2025 FIG and the TRF
• Budget 2026 OOTLAR, Annex A: rates and allowances
• IRAS e-Tax Guide: Tax Exemption for Foreign-Sourced Income (Fifth Edition)

Raffles Corporate Services helps principals relocating from the UK with VCC incorporation, family office set-up and ongoing compliance, working alongside their UK tax advisers on the timing of each step. Email hello@rafflescorporateservices.com or Call/SMS/WhatsApp +65 8501 7133, or visit Raffles Corporate Services.

Last reviewed: 9 November 2026. The Editorial Team, Variable Capital Companies Act.