Compliance
UK’s Transfer Pricing Schedule Consultation: Getting Ready for Reporting from 2027
With the UK’s ICTS coming into effect for accounting periods from 1 January 2027, multinationals with presence in the UK need to understand design, template, and reporting burdens now.
By NomadicTax Research Team • 5-8 min read • August 27, 2026
## What is the UK’s International Controlled Transactions Schedule (ICTS)?
In June 2026, the UK government launched **a technical consultation** on draft regulations for the **International Controlled Transactions Schedule (ICTS)**. This reporting requirement will affect multinationals operating in the UK, especially those already subject to transfer pricing or permanent establishment rules. ([gov.uk](https://www.gov.uk/government/consultations/transfer-pricing-international-controlled-transactions-schedule/the-international-controlled-transactions-schedule-icts?utm_source=openai))
Key points from the consultation notice:
- The ICTS will require in-scope multinationals to report detailed information about international related-party transactions on a standard schedule.
- ICTS is set to take effect for accounting periods **beginning on or after 1 January 2027**. ([gov.uk](https://www.gov.uk/government/consultations/transfer-pricing-international-controlled-transactions-schedule/the-international-controlled-transactions-schedule-icts?utm_source=openai))
- The template for reporting follows the UK’s Finance Act 2026 powers and aims to support HMRC’s risk-assessment and audit targeting.
## Implications for Multinational Entities
### What kinds of entities likely in scope
- Companies with substantial related-party international transactions or significant permanent establishments in the UK.
- Multinational corporations with centralized finance functions, related-party loans, royalties, or service charges.
### Reporting requirements and burdens
- ICTS will require consistent preparation of data that aligns with financial statements submitted in annual tax returns.
- Template pilot schedules are made available during consultation; ensuring your financial systems can generate the required data is crucial.
### Risk mitigation for reporting disputes
- Early engagement with transfer pricing policies to ensure documentation supports the data to be reported.
- Ensure consistency across jurisdictions in how terms (e.g. arm’s-length, permanent establishment) are defined and used.
## Example Scenario
A US company with a UK subsidiary paying service fees to its US parent company: under ICTS, the UK subsidiary will need to report those controlled transactions in detail, showing amounts, the nature of service, cost base, margins, etc.—not just the amount paid, but relevant comparables and transfer pricing basis.
If two UK-subsidiary accounting periods straddle 1 January 2027, the one beginning after that date must be ICTS-compliant.
## Recommended Actions Before 2027
- Begin mapping all related-party cross-border transactions, classify them by type (loans, royalties, services).
- Review your accounting and tax systems to ensure they can capture the required data fields.
- Consult with your advisers or local counsel to comment on the draft regulations during the consultation period (which runs through 31 July 2026) to influence template design.
- Prepare updated transfer pricing documentation to match the level of disclosure ICTS will require.
The ICTS signals a shift toward more granular, automated data-led compliance. Entities that prepare ahead will benefit from smoother reporting and fewer audit surprises.