HMRC has launched a consultation on a proposed International Controlled Transactions Schedule (ICTS) reporting requirement to support transfer pricing risk assessment for in-scope multinationals, with implementation planned from 1 January 2027.
The UK’s His Majesty’s Revenue and Customs (HMRC) has launched a technical consultation regarding cross-border related party transactions on 16 June 2026, inviting views on the details of a draft International Controlled Transactions Schedule (ICTS) reporting requirement.
At Budget 2025, the government announced its decision to implement the ICTS. 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.
This measure is intended to:
- improve fairness: ensuring multinational enterprises pay tax on profits generated from economic activity in the UK
- increase efficiency: meaning that HMRC compliance activity can be more effectively targeted, benefiting compliant taxpayers
In this consultation, the government is seeking views on draft regulations and a draft HMRC notice, which detail the ICTS reporting requirement. A draft template illustrating the information that would need to be reported to HMRC (as described in the draft HMRC notice) is shown in the Draft ICTS Template 2026 attachment.
It should be noted that the use of Excel to depict the ICTS template is entirely illustrative, for convenience, and not indicative of IT design. HMRC will work collaboratively with software providers, other intermediaries and end users on the IT design of the ICTS. They will look to ensure the final design minimises burdens and reflects user needs, consistent with HMRC’s strategic approach to third-party software.
The government welcomes suggestions from stakeholders on how its aims can be achieved whilst limiting additional administrative burden on businesses.
This consultation document is intended for businesses currently within the scope of the UK transfer pricing or permanent establishment legislation, as well as advisory firms, representative bodies and legal firms that provide services to or represent those businesses.
The consultation will run until 31 July 2026.
