The new tax year has arrived and the long-term residence rules are now in play irrespective of whether tax practitioners and HMRC are ready to deal with the full implications.
One area of particular interest especially following amendments adopted during the passage of the Finance Bill through parliament to royal assent on 20 March 2025 is the new temporary repatriation facility (TRF).
What are the TRF rules?
HMRC has brought the remittance basis of taxation to an end and replaced it with a simplified residence-based tax regime. For a full outline of the new rules prior to the amendments incorporated into Finance Act 2025 Sch 10 see ‘Non-dom reforms: is it all doom and gloom?’ by Sharlene Rowley (Taxation 9 December 2024).
One of the changes is the introduction of the TRF which is intended to encourage individuals who were previously taxed on the...
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