UK and International Tax news
The International Controlled Transactions Schedule
Tuesday 30th June 2026
HMRC has launched a consultation on details of a draft International Controlled Transactions Schedule (ICTS) reporting requirement.
In the Budget 2025, the government announced its decision to implement the ICTS, and Finance Act 2026 gave the Commissioners of HMRC the power to introduce regulations requiring in-scope multinationals to file an ICTS. The government intends that the ICTS reporting requirement will take effect for accounting periods beginning on or after 1 January 2027.
The ICTS will facilitate automated, data-led risk assessment by HMRC, permitting more accurate identification of transfer pricing risk. It will increase efficiency by promoting tax compliance at the earliest opportunity and reducing the length of transfer pricing enquiries. Taxpayers will benefit from shorter, better targeted enquiries from HMRC that are focused on cases where adjustments to transfer pricing are required.
The measure is intended to improve fairness ensuring multinational enterprises pay tax on profits generated from economic activity in the UK. It is also intended to increase efficiency so that HMRC’s compliance activity can be more effectively targeted, benefiting compliant taxpayers.
The government is seeking views on draft regulations, a draft HMRC notice and a draft template illustrating the information that would need to be filed annually.
HMRC advises that the use of Excel to depict the ICTS template is entirely illustrative, for convenience, and not indicative of IT design, as HMRC will work collaboratively with software providers, other intermediaries and end users on the IT design of the ICTS. HMRC intends for the final design to minimise burdens and reflects user needs, consistent with their strategic approach to third-party software.
The consultation will run from 16 June 2026 to 31 July 2026 and responses received will feed into the drafting of the statutory instrument which the government expects to lay later in 2026. Consultation responses will also inform the notice which HMRC intends to publish by the end of 2026.
If you would like more information on the above, please contact Keith Rushen on 0207 486 2378.
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