Tax advisers will be scrutinising Monday’s pre-Budget report for evidence that the government has had a change of heart on its foreign profits plans.

The moves, which will tighten up the taxation of offshore subsidiaries – which the Treasury believes are for tax avoidance – have alienated companies, some of which have announced plans to leave the UK.

Bill Dodwell, Deloitte tax partner, said business needs clarification from the Treasury on the direction of the Controlled Foreign Companies (CFC) laws.

‘Unless they relax laws in the future then they’re going to see companies emigrate. Are we going to see some improvements from the PBR? No-one is leaving because they don’t have a dividend exemption,’ he said.

The ‘Treasury Consent’ regime is likely to be abolished, advisers also believe.

Many argue the concept of the regime has been effectively redundant for some 20 years. Currently, if UK-based companies issue shares or debt overseas, they must seek government permission.