International movement of capital

This Overview summarises the circumstances in which the post-transaction reporting obligations known as the international movement of capital rules (which replaced the Treasury Consent rules) are imposed on a UK company under Schedule 17 to the Finance Act 2009.

Whenever:

    •a directly or indirectly controlled foreign subsidiary of a UK tax resident company:◦issues shares or debentures, or◦becomes or ceases to be entitled to more than 50% of a partnership, or•shares or debentures in a directly or indirectly controlled foreign subsidiary of a UK tax resident company ...

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Practice notes

International movement of capitalThe international movement of capital rules should be considered whenever:•any non-UK tax resident subsidiary...
12th Jun
Precedents

Letter—report regarding the international movement of capital[Letterhead][Addressed to reporting body’s customer compliance manager (CCM) or, if none,...
21st May

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