The UK has made new regulations requiring companies and partnerships to report cross-border related party dealings to the tax authority each year, for accounting periods beginning on or after 1 January 2027.
The UK’s HM Revenue & Customs (HMRC) has introduced new regulations requiring certain companies and other entities to report information on international controlled transactions, including cross-border transactions subject to transfer pricing rules and transactions involving permanent establishments. The International Controlled Transaction Reporting Regulations 2026 (S.I. 2026/1156), made on 30 October 2026, set out who must report, which transactions are covered, applicable exemptions, filing deadlines and penalties for non-compliance.
Scope of reporting
Reporting is required when the total value of specified international controlled transactions, individually or aggregated, meets a threshold requirement. The threshold will be set in a future HMRC notice, and further notices will specify what must be reported.
A transaction is covered if it meets the Transfer Pricing Condition, the Permanent Establishment (PE) Condition, or both. The first covers cross-border controlled transactions subject to transfer pricing rules under Part 4 of the Taxation (International and Other Provisions) Act 2010 (TIOPA 2010) and the Finance Act 2026. The second covers transactions attributed to the UK permanent establishment of a non-UK resident company, or to a foreign permanent establishment of a UK resident company.
Who must report and exceptions
Reporting entities include UK resident companies, non-UK resident companies, representative partners of partnerships and managing agents of Lloyd’s syndicates, depending on the condition that applies.
Exceptions cover transactions outside basic transfer pricing calculation rules under sections 165 or 166 of TIOPA 2010, distributions within section 1000 of the Corporation Tax Act 2010, transactions covered by an advance pricing agreement, those assessed as low-risk under the OECD International Compliance Assurance Programme, registered charities and companies wholly owned by charities, and information already submitted for the same period.
Deadlines
For non-managing agents, the deadline for accounting periods ending on or before 30 September 2027 is the later of 30 September 2028 or the date specified in an HMRC notice. For later periods, it is the statutory filing deadline of the corresponding tax return. Managing agents must file by the later of the Lloyd’s syndicate return filing date or the date set by HMRC notice.
The information must be accurate, free of material error or omission and consistent with the relevant tax return. Entities must amend it if the underlying return changes, an exception ceases to apply or inaccurate data was supplied.
Penalties
An initial failure to comply attracts a penalty of GBP 300 per accounting period or underwriting year. A continuing failure brings a daily default penalty of up to GBP 60 per day, rising to up to GBP 1,000 per day if HMRC applies to the Tribunal after 30 days. Inaccurate information carries a penalty of up to GBP 3,000 where the error is careless or deliberate.
No failure penalty applies where the person shows a reasonable excuse, although insufficiency of funds and reliance on a third party are excluded. Appeals must be lodged in writing with HMRC within 30 days of notification.
The regulations were laid before the House of Commons on 4 November 2026 and came into force on 26 November 2026. They also apply to underwriting years beginning on or after 1 January 2027, where syndicate profits or losses must be declared on or after 1 January 2030.
