United Kingdom Transfer Pricing Regulatory Update

The International Controlled Transactions Schedule (ICTS) is a reality

The UK government has confirmed the introduction of the International Controlled Transactions Schedule (ICTS).

Key Updates:

– Effective Date: Accounting periods beginning on or after 1 January 2027.

– Requirement: Standardized disclosure of cross-border related-party transactions, significantly increasing the information companies must disclose, to feed directly into HMRC’s risk-profiling systems.

– Thresholds: Yet to be finalized. If the original proposal of a GBP 1m+ related party transactions threshold is implemented, it will bring many groups into scope.

– Next Steps: Further consultation on draft legislation, including details on filing format and methods, is expected in Spring 2026.

Sources:

– GOV.UK: Transfer pricing: international controlled transactions schedule (https://www.gov.uk/government/publications/transfer-pricing-international-controlled-transactions-schedule)

– GOV.UK: Transfer pricing scope and documentation — Summary of responses (https://www.gov.uk/government/consultations/transfer-pricing-scope-and-documentation/outcome/transfer-pricing-scope-and-documentation-summary-of-responses)

Reach out to paul.valdivieso@basefirma.com with any questions

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