Transfer pricing: international controlled transactions schedule

The government is introducing legislation to give HMRC commissioners the power to introduce regulations requiring in-scope multinationals to file an international controlled transactions schedule (ICTS).

The ICTS is expected to be an annual filing requirement that captures specific information about cross-border related party transactions in a standardised format. The information will be used for automated risk profiling and manual risk assessment by HMRC.

This legislation follows a policy consultation on the ICTS proposal at Tax update spring 2025: simplification, administration and reform (TUSAR). A technical consultation on draft regulations will be held in Spring 2026.

This change is expected to take effect for accounting periods beginning on or after 1 January 2027.