Foreign Profits Reforms – Proposals Deferred Beyond 2009

On 21 July 2008, 13 months after launching a consultation on reforming the United Kingdom's regime for the taxation of companies' foreign profits, HM Treasury released an update.

Since HM Treasury launched a consultation on reforming the United Kingdom's regime for the taxation of companies' foreign profits 13 months ago, the subject of taxation generally has become a political hot potato, with the Government forced rather hurriedly to revise a number of proposed reforms to the tax system amid a shower of hostile headlines. The proposed foreign profits reforms provoked a similar reaction, with several major UK companies deciding to "migrate" their head offices out of the United Kingdom by incorporating new ultimate holding companies resident elsewhere, and others announcing that they were actively considering taking such steps. The Treasury therefore issued a technical note on 12 July 2008, partly to