INTM917310 - DRAFT: The International Controlled Transactions Schedule (ICTS): Glossary of terms
This guidance is in draft. It covers the International Controlled Transaction Reporting Regulations 2026 (‘the Regulations’), which were laid before the House of Commons on 4 November 2026. HMRC aims to publish the ICTS notice on 26 November 2026 (when the Regulations come into force), and detailed guidance on the ICTS notice in this manual by 31 December 2026, prior to the reporting requirement coming into effect from 1 January 2027.
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A
Accounting Period (Regulations)
Accounting period is defined by section 1119 of the Corporation Tax Act 2010
Accurate (Regulations)
Regulation 9 specifies that "information is accurate if it is consistent with the analysis used to complete the relevant return, correctly reflects the matters to which it relates and does not contain any material error or omission".
Advance pricing agreement (APA) (Regulations)
An advance pricing agreement is an agreement made under Part 5 TIOPA 2010 in relation to one or more of the matters described in section 218(2). Further guidance on APAs is at INTM422020.
Advantaged person (Regulations)
Under regulation 15, 'advantaged person' takes its meaning from TIOPA10/Part4. There is guidance on advantage at INTM412020
Aggregation (Regulations and notice)
Under regulation 7(3), where required in a notice published by the Commissioners, specified information related to one or more SICTs must be aggregated and provided to an officer of Revenue and Customs in a single entry.
Amendment deadline (Regulations)
The date by which specified information may be amended (regulation 10(3)) or must be amended (regulation 10(2)). This deadline is specified at regulation 13.
C
Careless (Regulations)
Under regulation 21, careless takes its meaning from TMA70/S118(5) and (6).
Charity (Regulations)
Under regulation 5, charity is defined in FA10/Sch6/Para1
CTA2009 (Regulations)
Corporation Tax Act 2009, as defined in FA26/S281, the interpretation provision of that Act. Also cited as CTA09.
CTA2010 (Regulations)
Corporation Tax Act 2009, as defined in FA26/S281, the interpretation provision of that Act. Also cited as CTA10.
D
Deliberate (Regulations)
Under regulation 21, deliberate takes its meaning from TMA70/S118(7).
Distribution (Regulations)
Under regulation 15, distribution takes its meaning from CTA10/S1000.
E
Exception (Regulations)
There are exceptions to the reporting requirement for certain entities or certain transactions. These are found at regulation 5 and regulation 15.
F
FA2026 (Regulations)
Finance Act 2026. Section 48 of FA2026 has the ICTS primary legislation. Also referenced as FA26.
Foreign permanent establishment (Regulations)
Under regulation 14, foreign permanent establishment has the meaning as at CTA09/CH3A.
I
ICAP Handbook (Regulations)
Under regulation 15(6) the ICAP Handbook means the ICAP Handbook for tax administrations and MNE groups published by the OECD on 18 February 2021 (as amended from time to time) as interpreted in accordance with, or supplemented by, such documents as may be published by the OECD from time to time as are relevant to the application of ICAP.
International controlled transaction (Finance Act 2026)
Any transaction that meets the transfer pricing condition or the permanent establishment condition. It is possible for a transaction to meet both conditions, and this would be an international controlled transaction for both conditions. If the transaction meets the requirements to be 'specified' as outlined in the regulations, it may need to be reported under each condition. FA26/S48(3)(b)
International Compliance Assurance Programme (ICAP) (Regulations)
Under regulation 15, ICAP means the International Compliance Assurance Programme, administered by the OECD
M
Managing agent (Regulations)
Under regulation 2, managing agent has the same meaning as in the Lloyds Underwriters (Tax) Regulations 2005 (LTUR05)
Member (Regulations)
Under regulation 2, member has the same meaning as in the FA94/S230
P
Participation condition (Finance Act 2026)
This refers to the participation condition as at TIOPA10/S148. Guidance on the participation condition can be found at INTM414210
Partnership (Regulations)
Regulation 2(1) explains that for the purposes of the reporting requirement, the definition of partnership is extended to Limited Liability Partnerships (LLPs)
Permanent establishment (Regulations)
Under regulation 14, permanent establishment has the same meaning as in CTA10/S1141
Permanent establishment condition (Finance Act 2026)
Defined in FA26/S48(5) as where a transaction is relevant to the determination of either an exemption adjustment under CTA09/S18A, or the profits of a non-UK resident company that are (for the purposes of the Corporation Tax Acts) attributable to a permanent establishment of the company in the UK.
Provision (Finance Act 2026)
This refers to the term ‘provision’ as at TIOPA10/S147(1)(a). Guidance on the provision can be found at INTM412050
R
Relevant partner (Regulations)
Regulation 2(1) defines a relevant partner as a person who was a partner in the partnership to which the relevant return relates at any time during the period in respect of which the relevant return was required, including the representative partner.
Relevant return (Regulations)
Regulation 2(1) defines relevant return as the underlying tax return where the transaction meeting the criteria to be a SICT has been reported to HMRC.
Relevant returns are the:
- company tax return required to be delivered under paragraph 3 of Schedule 18 to the Finance Act 1998,
- partnership return required to be delivered under section 12AA of the TMA 1970, or
- syndicate return required to be delivered by regulation 4(1) of The Lloyd’s Underwriters (Tax) Regulations 2005
Further detail on the interaction between the relevant return and the reporting requirement is at regulation 9 on accuracy.
Reporting entity (Regulations)
Regulation 2(1) defines the reporting entity as the entity obliged to fulfil the reporting requirement (see regulations 16 and 17 for details)
Representative partner (Regulations)
Regulation 2(1) defines the representative partner as the partner who is required to make and deliver the relevant return to which the specified international controlled transaction relates, or that partner’s successor, in accordance with section 12AA of the TMA 1970
S
Specified information (Regulations)
Regulation 2(1) defines specified information as the information required to be reported. There is a fuller explanation at regulation 18.
Specified international controlled transaction (SICT) (Regulations)
Regulation 2(1) defines a specified international controlled transaction as the transactions that must be reported. There is a fuller explanation at regulation 14.
Submission deadline (Regulations)
The date by which specified information must be reported. This is specified in regulation 6.
Syndicate (Regulations)
Under regulation 2(1) syndicate takes its meaning form FA93/S184(1)
T
Threshold requirement (Regulations and notice)
Under regulation 4, the Commissioners can specify a threshold requirement in a notice. There is a requirement under regulation 4 to report SICTs that meet the threshold requirement, subject to exceptions at regulation 5.
TIOPA2010 (Regulations)
Taxation (International and Other Provisions) Act 2010, as defined in FA26/S281, the interpretation provision of that Act
TMA1970 (Regulations)
Taxes Management Act 1970, as defined in FA26/S281, the interpretation provision of that Act
Transaction (including series of transactions) (Finance Act 2026)
This refers to transaction as at TIOPA10/S150. Guidance on transaction can also be found at INTM412050. FA26/S48(6) states that reference to a transaction includes any transaction that may be treated to have occurred for the purposes of applying Chapter 3A or 4 CTA09/Part2.
Transfer pricing condition (Finance Act 2026)
Defined in FA26/S48(4)
Tribunal (Regulations)
Regulation 2(1) defines tribunal as the First-tier Tribunal, or, where determined by or under Tribunal Procedural Rules, the Upper Tribunal.
U
Underwriting year (Regulations)
Under regulation 2 this takes its meaning from FA93/S184(1)