Income Tax Act 2007 section 809RZB

TRF capital account

Section 809RZB sets out the rules for nominating a bank account as a Temporary Repatriation Facility (TRF) capital account, including the qualifying conditions, time limits for notification, and the circumstances in which such an account begins and ceases to have TRF capital account status.

• An individual can nominate one or more ordinary bank accounts as TRF capital accounts by written notice to HMRC, specifying a qualifying date — the first date on which more than £10 of TRF capital is paid in when the existing balance is £10 or less.
• The account must be an ordinary bank account (current or savings) held by and for the benefit of the individual, with a pre-qualifying-date balance of no more than £10; any such small opening balance and any interest earned on TRF capital in the account are automatically treated as TRF capital.
• The nomination (or its withdrawal) must be notified in writing by 31 January following the tax year in which the qualifying date (or withdrawal date) falls, unless HMRC allows a later deadline.
• TRF capital account status runs from the qualifying date until the earliest of the account closing, the nomination being withdrawn, or 6 April in a tax year containing an unremedied breach of the TRF deposit rule — and the account never qualifies at all if such a breach occurs in the tax year of the qualifying date itself.