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:
1. ◦
  issues shares or debentures, or
2. ◦
  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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