Transfer pricing

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FORTHCOMING CHANGE relating to the new ‘International Controlled Transactions Schedule’: At Budget 2025, the government announced that it would be proceeding with a requirement for in-scope multinationals to report information annually on cross-border related party transactions for accounting periods beginning on or after 1 January 2027. A consultation on this measure had run from April to July 2025. (See News Analysis: Budget 2025—Tax analysis—International.) The technical regulations for this new ‘International Controlled Transactions Schedule’ (ICTS) were published for technical consultation on 16 June 2026, along with a draft ICTS notice and template illustrating the information that would need to be filed. The consultation closed on 31 July 2026.

FORTHCOMING CHANGE relating to the OECD Transfer Pricing Guidelines: On 1 June 2026, the OECD opened a public consultation on proposed revisions to Chapter VII of its Transfer Pricing Guidelines, covering special considerations for intra-group services. The OECD stated that the revisions are not intended to change the general principles underlying the transfer pricing analysis of intra-group services; rather, their primary objective is to ensure alignment between this guidance and the foundational principles in Chapters I, II and III, to...

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