UK: International controlled transactions schedule (ICTS) intended to apply beginning January 1, 2027
Professional services businesses owning interests in entities required to file UK corporation tax returns will need to consider the new ICTS requirements.
The international controlled transactions schedule (ICTS)—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—is intended to apply to accounting periods beginning on or after January 1, 2027.
The information will be used by HMRC for automated transfer pricing and PE risk profiling and identification.
The ICTS generally will apply only to companies subject to UK corporation tax (including nonresident companies trading in the UK through a PE), but other entities such as professional services businesses that own interests in entities required to file UK corporation tax returns will need to consider the new ICTS requirements.
The ICTS is expected to cover specific information for each reportable category of cross-border controlled transaction or PE dealing. For professional services businesses, the most relevant categories are likely to be services, financing, and intellectual property (IP).
Read a September 2026 report prepared by the KPMG member firm in the UK