INTM917320 - DRAFT: The International Controlled Transactions Schedule (ICTS): Introduction to the ICTS
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.
A Statutory Instrument for the ICTS secondary legislation is currently laid in the House of Commons, and the provisions are not yet in force.
The International Controlled Transaction Schedule (ICTS) will be an annual reporting requirement for in-scope multinational enterprises (MNEs) to submit information in relation to their international controlled transactions to HMRC. The aim of this reporting requirement is to support more accurate identification of risk for two areas within international tax: the transfer pricing and permanent establishment rules.
MNEs in-scope of the measure will be required to report information on their cross-border, related-party transactions in a standardised dataset. This will allow HMRC to capture specific factual details to be used for automated, data led risk profiling and manual risk identification.
For both transfer pricing and permanent establishment, HMRC need to be able to determine if the transfer pricing and profit attribution rules are being accurately adhered to. All businesses are required to keep records to make and deliver a complete and correct tax return. UK entities in scope of transfer pricing and permanent establishment legislation need to demonstrate that related party transactions have been identified and priced in accordance with legislation.
The reporting requirement will capture specific factual data on transaction between UK businesses and their connected parties outside the UK, where those transactions meet criteria and thresholds set out in a HMRC notice. The information provided will be in a standardised digital format that will facilitate automated data-led risk profiling, permitting more accurate identification of international tax risk.