In combining the two revenue departments into one, the Act implemented the recommendation of the O'Donnell Review. The Act provides for the new department to inherit the powers of the old departments, pending a comprehensive review of revenue powers. Following some controversy in the Parliamentary debates, the Act also expressly provides for a duty to keep information confidential, with criminal penalties for wrongful disclosure.
The Bill that became the Act was introduced to Parliament in the House of Commons on 24 November 2004, completed its stages in the House of Commons on 16 January 2005, completed its stages in the House of Lords on 5 April 2005. Lords' Amendments were considered by the House of Commons on 6 April 2005 and the Act received Royal Assent on 7 April 2005. The merger of the revenue bodies, and creation of RCPO, took effect 11 days later.