The timing of the introduction is not yet certain. Typically such legislation applies from date of enactment (which is likely to be summer 2009 in the case of the Finance Act 2009), but earlier or later dates are possible.

The proposals represent a major change to the UK international tax regime, and will have a significant impact on the tax profile of many international groups with UK operations, both inbound and outbound groups. While there are likely to be some alterations to the draft legislation, the direction of travel is clear, and is consistent with earlier consultations.

The key changes will be: