Transfer pricing

Transfer pricing

FORTHCOMING CHANGE relating to UK transfer pricing legislation: Finance Bill 2026 (as introduced) contains provisions which make multiple changes to the UK’s transfer pricing legislation. With effect for accounting periods beginning on or after 1 January 2026, when enacted these measures will, amongst other things, remove UK-to-UK transfer pricing (subject to exclusions in order to prevent opportunities for tax arbitrage), amend the participation condition, clarify that the OECD Model Tax Convention and OECD Transfer Pricing Guidelines are interpretative aids, and make several changes to the provisions governing financial transactions to better align the UK rules with the OECD Transfer Pricing Guidelines. Alongside these changes, the government also announced at Budget 2025 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 after 1 January 2027—the technical regulations for this new ‘International Controlled Transactions Schedule’ (ICTS) are expected to be published in spring 2026. For more on the changes being made, see News Analyses: Finance Bill 2026—reform of UK law in relation to transfer pricing, permanent establishment and diverted profits tax,

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