UK to implement new international controlled transactions filing requirement

The new filing obligation represents a significant shift in UK transfer pricing compliance and risk management, as outlined by KPMG UK’s Phil Roper.

The United Kingdom (UK) Chancellor has confirmed the UK Government will press ahead with granting His Majesty's Revenue and Customs (HMRC) new powers to require certain taxpayers to file an annual International Controlled Transactions Schedule (ICTS). This will capture standardised information on cross-border related party transactions and will be used for both automated and manual risk assessments. The ICTS represents a significant shift in UK transfer pricing compliance and risk managemen...

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Authors: Phil Roper

Published Date: 28 November 2025