# Finance Act 2026, Paragraph 12: Income tax or capital gains tax reduction where TRF charge paid on same amount

Extent: E+W+S+N.I.

In paragraph 8, after sub-paragraph (6) insert—
“(6A) Sub-paragraph (6B) applies where—
(a) an amount (“the TRF amount”) is treated as designated qualifying overseas capital of an individual as a result of sub-paragraph (6),
(b) on or after 6 April 2025, an officer of Revenue and Customs, in relation to the tax year 2024-25 or an earlier tax year—
(i) amends the individual’s self-assessment while an enquiry under section 9A of TMA 1970 (enquiry into return) into the individual’s return for that tax year is in progress,
(ii) issues a partial or final closure notice under section 28A of that Act (completion of enquiry) in relation to that return, or
(iii) makes an assessment under section 29 of that Act, and
(c) the effect of the officer taking that step is that income tax or capital gains tax is charged in respect of the TRF amount.
(6B) The amount of income tax or capital gains tax due and payable under section 59B of TMA 1970 in respect of the TRF amount is to be treated as reduced (but not below nil) by the amount of the TRF charge paid in respect of the TRF amount.
(6C) Where sub-paragraph (6B) applies, the individual may not amend the return in which the designation election relating to the TRF amount was included to alter or revoke that election (if the return otherwise could have been amended) so as to cause the TRF amount not to be designated.”

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Source: https://www.legislation.gov.uk/ukpga/2026/11/schedule/3/paragraph/12 (the official version)
Page: https://openlegislation.uk/finance-act-2026/schedule-3/paragraph-12
Contains public sector information licensed under the Open Government Licence v3.0. Source: legislation.gov.uk, The National Archives.