Log in or register
Share on LinkedInShare on LinkedIn

ARTICLE · 14 JULY 2026

UK Tax Authority Will Transform Transfer Pricing Risk Assessment

Macfarlanes LLP
Macfarlanes LLP
Contributor
Macfarlanes LLP

Macfarlanes LLP

Macfarlanes is a distinctive London-based law firm with a unique combination of services built and...

View firm profile
Explore more from Macfarlanes LLP

The UK's new International Controlled Transactions Schedule (ICTS) will fundamentally transform how HMRC assesses transfer pricing risks, shifting from documentation-focused reviews to data-driven analysis powered by AI and advanced analytics. With mandatory filing beginning January 1, 2027, multinational enterprises must prepare to provide detailed, standardized information about cross-border related party transactions, facing unprecedented scrutiny and visibility of their transfer pricing arrangements.

United KingdomTax
Sarah Ling
Sarah Ling
Wai Wan
Wai Wan
Bahar Eken
Bahar Eken

This article was first published in Bloomberg Tax on 13 July 2026.

The UK released its latest consultation document on the International Controlled Transactions Schedule, or ICTS, on June 16. This new annual filing requirement will transform transfer pricing risk assessments for both the UK tax authority, HM Revenue & Customs, and taxpayers, shifting from a documentation-focused process to a data-driven one.

The ICTS, coupled with ever more powerful AI and data-analytic tools, represents a fundamental shift in HMRC’s approach to risk assessment. HMRC will be better informed than ever to identify inconsistencies, errors, outliers, unusual patterns, and year-on-year trends across taxpayers and their peers. Businesses should prepare for heightened scrutiny and visibility of their transfer pricing arrangements.

We operate a free-to-view policy, asking only that you register in order to read all of our content. Please login or register to view the rest of this article.

Register for freeORLog in

The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.

View source

Related Articles

Legal Intelligence Newsletters: sign up for the latest legal and regulatory news on your chosen topics

Read more about

Related Comparative Guides

See more popular content from

Article

Frequently Asked Questions About IRS Clearance And Form 706-NA

UK executors and beneficiaries dealing with US assets face significant delays in obtaining IRS Transfer Certificates, with waiting times now extending to two or three years. This comprehensive FAQ addresses the critical questions surrounding Form 706-NA applications, US estate tax requirements, and the practical challenges of administering estates containing US shares and investments when the deceased was not a US citizen.
GlobalTax
Lester Aldridge LLP
Lester Aldridge LLP
Article

UK ‘Windfall’ Bank Tax Would Worsen An Already Complex System

UK banks face the prospect of a new windfall tax as campaigners push for additional levies on strong reported profits, while industry leaders warn of potential consequences for lending, investment, and the UK's position as a global financial centre. This analysis examines the practical implications of adding another layer to an already complex sector-specific tax regime that includes corporation tax, banking surcharge, and bank levy.
United KingdomTax
RPC
RPC
Article

Tribunal Limits HMRC's Schedule 36 Powers In Transfer Pricing Case

When HMRC issued an information notice demanding a UK subsidiary's US parent company financial statements in a transfer pricing enquiry, the First-tier Tribunal had to determine whether such documents were reasonably required and whether the subsidiary had the power to obtain them. The case examines the boundaries of HMRC's information-gathering powers and the practical limits of corporate group relationships.
European UnionTax
RPC
RPC
Article

Transfer Pricing Enquiries: HMRC’s Approach And Recent Cases

Transfer pricing litigation in the UK has historically been rare, but recent procedural cases reveal HMRC's increasingly aggressive approach to enquiries. With average enquiry durations now exceeding 40 months and transfer pricing yield surging to £3.4bn, understanding the legal boundaries of information requests and closure notice applications has become critical for multinational groups facing contentious disputes.
United KingdomTax
Macfarlanes LLP
Macfarlanes LLP
Article

Reward Autumn Update 2026

The autumn 2026 edition of the Reward update examines significant proposals to reform directors' remuneration reporting requirements, including changes to the DRR and removal of the annual shareholder advisory vote. It also covers FCA consultation on solo-regulated firms' remuneration, the impact of Employment Rights Act changes on share plans, equal pay reform proposals, and updates to AIM rules affecting corporate governance and remuneration disclosure.
United KingdomEmployment and HR
Macfarlanes LLP
Macfarlanes LLP
Article

Broadcom/VMware: EU General Court Again Weighs In Favour Of Commission’s Broad Information Gathering Powers

The European Commission's broad information-gathering powers under EU competition law have been reinforced by the General Court's dismissal of Broadcom's challenge to document production requests. The case raises critical questions about the extent to which the Commission can compel production of documents held overseas that are subject to legal professional privilege in other jurisdictions, particularly communications with non-EU qualified external counsel.
European UnionAntitrust/Competition Law
Macfarlanes LLP
Macfarlanes LLP
Article

Investment Management Update - September 2026

The Financial Conduct Authority has released a comprehensive package of regulatory updates and findings covering investment management, wealth management, and consumer protection. Key developments include reforms to MiFID costs and charges disclosures, remuneration code changes, AIFM regime overhauls, and detailed reviews of firms' Consumer Duty compliance, financial crime controls, and governance frameworks.
United KingdomFinance and Banking
Macfarlanes LLP
Macfarlanes LLP
Article

Investing In Infrastructure: The Capital Stack

The infrastructure capital stack is undergoing significant transformation as equity markets consolidate at the top while creating mid-market opportunities, private debt emerges as a bankability indicator for maturing sectors, and fund finance structures become increasingly sophisticated. This evolution is reshaping how capital is deployed, structured, and exited across the infrastructure investment landscape...
United KingdomFinance and Banking
Macfarlanes LLP
Macfarlanes LLP
Article

Sponsored Repo And US Treasury Central Clearing – What The Buy-side Needs To Know

The US Treasury repo market faces a fundamental transformation as SEC rules mandate central clearing for most Treasury repurchase transactions by June 2027. This regulatory shift is accelerating buy-side adoption of "sponsored repo" arrangements, requiring firms to navigate new operational frameworks, documentation requirements, and clearing relationships. Understanding the mechanics of sponsored membership and preparing for compliance will be critical for buy-side participants seeking to maintain efficient
United StatesFinance and Banking
Macfarlanes LLP
Macfarlanes LLP
Article

Few Surprises, As The CMA Finalises Its Revised Approach To Merger Efficiencies

The UK Competition and Markets Authority has formalised its new approach to assessing efficiency arguments in merger control cases, marking a significant shift toward a more holistic evaluation framework. This updated guidance, which emerged from the CMA's 4Ps initiative, introduces the concept of Rivalry-Enhancing Efficiencies and establishes clearer pathways for merging parties to demonstrate competitive benefits.
United KingdomAntitrust/Competition Law
Macfarlanes LLP
Macfarlanes LLP
Article

Transfer Pricing Enquiries: HMRC’s Approach And Recent Cases

Transfer pricing litigation in the UK has historically been rare, but recent procedural cases reveal HMRC's increasingly aggressive approach to enquiries. With average enquiry durations now exceeding 40 months and transfer pricing yield surging to £3.4bn, understanding the legal boundaries of information requests and closure notice applications has become critical for multinational groups facing contentious disputes.
United KingdomTax
Macfarlanes LLP
Macfarlanes LLP
Article

The New EU FDI Screening Regulation: (Un)welcome Changes For Dealmakers

The European Union's new foreign direct investment screening regulation introduces significant procedural improvements and standardised risk assessment criteria, while simultaneously expanding the scope of mandatory filings and eliminating preferential treatment for allied investors. Understanding how these changes will affect cross-border transactions and what steps dealmakers should take during the 18-month transition period is crucial for navigating the reformed regulatory landscape.
GlobalInternational Law
Macfarlanes LLP
Macfarlanes LLP