SolvedRDRM74100 | Temporary repatriation facility: Scope of designation: Overview
From HM Revenue & Customs · Remittance Basis and Domicile Manual
Overview
Amounts can only be designated under the temporary repatriation facility (TRF) if they meet the definition of qualifying overseas capital – see RDRM72100. However, these amounts may not simply be money in an overseas bank account. They may have been used to purchase overseas assets (see RDRM74300), or they may have been brought to the UK, for example, as exempt property (see RDRM74400) or having been invested in a UK company and business investment relief has been claimed (see RDRM74700). Amounts may be held within a mixed fund (see RDRM75100 onwards) or in a joint account (see RDRM74200).
Additionally, an individual may not have some of their foreign income and gains in their possession on 6 April 2025, either because those amounts are being held by someone else (see RDRM74500), or because they receive income during the TRF period that arose prior to 6 April 2025, such as earnings for a previous tax year (see RDRM74600).
Pre-2008 foreign income and gains
As with any other income and gains which arose in a period during which an individual was subject to the remittance basis, pre-6 April 2008 foreign income and gains can be designated under the TRF.
Pre-2012 foreign currency gains
Since 6 April 2012, gains on foreign currency bank accounts have been exempt from Capital Gains Tax (CGT). Pre-6 April 2012 foreign currency gains, which would have been subject to CGT on remittance, but which have not yet been remitted to the UK, can be designated under the TRF.