The UK’s planned International Controlled Transactions Schedule (ICTS) will give HMRC a more detailed, structured view of cross-border related-party transactions. For businesses in scope, it will introduce an annual reporting exercise that connects transaction amounts with the transfer pricing methods and financial results behind them.
At TP Genie, we are already working on ICTS support, which will form part of our TP Forms Module.
HMRC intends the requirement to apply to accounting periods beginning on or after 1 January 2027. The detailed regulations, notice and reporting template remain in draft, so businesses should prepare while allowing for changes to the final design. HMRC’s ICTS consultation
ICTS is designed to help HMRC identify transfer pricing risks through automated analysis and more targeted enquiries. It will sit alongside existing documentation requirements, giving the tax authority structured information about the transactions businesses undertake and how they price them. HMRC policy paper
The proposed disclosures cover several areas:
- Transactions and counterparties: What the entity buys, sells, provides or receives, and which related parties and jurisdictions are involved.
- Pricing methods and results: The methods applied, tested-party status, margins, mark-ups and relevant income and expenses.
- Financing arrangements: Loan balances, interest rates, terms, guarantees and relevant financial indicators.
- Intangibles and valuations: Transfers of intellectual property or businesses, including valuation methods and assumptions.
- Changes during the period: Restructurings, policy changes, tax adjustments and certain costs excluded from pricing calculations.
The information required depends on the transaction type, applicable thresholds and pricing methodology. HMRC’s draft reporting template
For groups with several UK companies, one practical point deserves particular attention: ICTS reporting is proposed at entity level. Each company that meets the filing conditions needs its own reporting assessment and entity-specific information. A consolidated UK total will not provide that detail. Draft regulations
Our view is that preparation should start with the connection between data and documentation. A local file may explain why a pricing policy is appropriate, while the figures needed to demonstrate its application sit across accounting systems, treasury records and local finance teams. ICTS preparation brings those sources together.
A useful first step is to take a completed financial year and work through the draft requirements. Identify the relevant UK entities, map their cross-border transactions to pricing policies, and check whether actual results can be reconciled to the accounts. This will help reveal missing counterparty information, inconsistent classifications or calculations that currently depend on manual work.
That is the practical preparation we want to help businesses address through our work on ICTS within TP Forms. We will share updates as development progresses and the reporting requirements become final.
We will also be discussing ICTS in webinars over the coming months, exploring the requirements and what they mean for transfer pricing teams.
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