Transfer pricing scope and documentation - International Controlled Transactions Schedule (ICTS)

The measure

Following a consultation earlier in 2025, the government has confirmed that it intends to introduce a new annual International Controlled Transactions Schedule reporting requirement. Businesses would report to HMRC cross-border related party transactional data in a structured format. HMRC would use this information for automated risk profiling and manual risk assessment.  

The same consultation also considered potential changes to the exemption from transfer pricing for small and medium-sized enterprises including the removal of the exemption for medium-sized enterprises. The government has decided that medium-sized enterprises will continue to benefit from the exemption.  

Who will be affected?

• UK businesses subject to transfer pricing rules;  
• UK businesses with foreign permanent establishments; and 
• foreign businesses with UK permanent establishments.  

When will the measure come into effect?

A technical consultation will be held in spring 2026 and the filing obligation is expected to apply to accounting periods beginning on or after 1 January 2027.