UK: Consultation on international controlled transactions schedule (ICTS)
The consultation will run until July 31, 2026.
HMRC on June 16, 2026, released a technical consultation on the draft implementing regulations, HMRC notice, and template forms for the international controlled transactions schedule (ICTS), reflecting a revised design and bringing with it new considerations. The consultation will run until July 31, 2026.
The ICTS will be an annual filing requirement, accompanying the tax return submission, that captures specific information about in-scope cross-border related party transactions and permanent establishment (PE) “dealings” in a standardized digital format. The information will be used by HMRC for automated transfer pricing and PE risk profiling and risk identification.
The ICTS has a broad scope which includes:
- UK resident businesses within scope of the transfer pricing legislation
- UK resident businesses with a foreign PE
- Foreign businesses with a UK PE
Read a June 2026 report prepared by the KPMG member firm in the UK
For more information, contact a KPMG tax professional in the UK:
Anna Lucey | anna.lucey@kpmg.co.uk
Rebekah Mitchell | rebekah.mitchell@kpmg.co.uk