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KPMG article: International controlled transactions schedule (ICTS) and UK transfer pricing

Overview of how the UK’s new ICTS reporting regime could transform transfer pricing compliance and risk assessment.

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September 17, 2026

The UK is preparing to introduce the most significant change to transfer pricing reporting in its history with its new international controlled transactions schedule (ICTS) reporting regime.

For many multinational enterprise groups outside the UK, the ICTS may appear to simply be the UK playing catch-up with similar reporting requirements that already exist in other countries. Some groups will have only a limited number of UK-related transactions within scope and may assume that the reporting obligation will therefore be straightforward. However, the ICTS design suggests a more nuanced picture.

Read an August 2026 article* prepared by KPMG UK tax professionals that explains what the ICTS is and why it will likely reshape the UK transfer pricing landscape by:

  • Exploring how the regime changes the information available to HMRC and its ability to assess transfer pricing risk
  • Highlighting several features that may be particularly relevant for foreign-owned groups with UK operations
  • Considering the practical and strategic questions taxpayers should address ahead of implementation

* This article originally appeared in Tax Notes International (August 31, 2026) and is provided with permission.

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