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Introduction

FA09/S37 provides for the repeal of the Treasury Consents legislation in ICTA88/S765 to 767 and its replacement with a requirement to report to HMRC the details of certain international transactions whose value exceeds 拢100 million. The detailed provisions are in FA09/SCH17.

These changes were introduced as a result of the Government鈥檚 review of the taxation of foreign profits and have effect for events or transactions taking place on or after 1 July 2009.

It is important to note that the new rules are limited to transactions whose value exceeds 拢100 million. In practice the new reporting requirement will therefore be restricted to large groups with substantial activities outside the United Kingdom. It does not have a general application in the way that the previous rules did.

FA09/SCH 17 is divided into three parts. Part 1 deals with the repeal of the Treasury Consents legislation (see INTM700200), part 2 outlines the reporting requirement (INTM700300 to INTM701000) and part 3 contains the commencement provisions (INTM701100).

FA09/SCH 17 contains a number of regulation making powers currently reflected in the International Movement of Capital (Required Information) Regulations, S.I. 2009/ No. 2192. Their provisions are described in the relevant parts of this guidance.