International movement of capital

During consultation on the taxation of foreign profits of companies an issue arose regarding the repeal of the current Treasury consent rules.

HMRC say that it was always intended that groups would have to comply with the new reporting requirement as of 1 July 2009 and that the current rules would be abolished with effect from that date.

However the current rules will remain in force until the Finance Bill receives royal assent.

To address any difficulty this overlap might create and to remove any uncertainty a Treasury minute has been tabled recording the Treasury's general consent to transactions entered into between 1 July 2009 and royal assent.

The effect of this and the current general consents is that no transaction entered into from 1 July 2009 will need to be notified in advance.

Under the new rules groups will need to report events...