Large groups must file annual related-party transaction reports from 2027

Multinational groups with United Kingdom transfer-pricing exposure must file HMRC a standardised annual account of their cross-border dealings with connected partiesLegislation from 1 January 2027Legislation. The International Controlled Transaction Reporting Regulations 2026 (SI 2026 No. 1156)Legislation impose the International Controlled Transactions ScheduleGOV: an annual, digitised return of factual data on transactionsLegislation between United Kingdom businesses and their connected parties outside the United KingdomLegislation that meet criteria and thresholds set by HMRCLegislation. It is the first exercise of the regulation-making power in section 48 of the Finance Act 2026Legislation, announced at Budget 2025Legislation.

The return feeds automated, data-led risk profiling for transfer-pricing and permanent-establishment risk, letting HMRC aim enquiries at higher-risk arrangements; compliant businesses should see fewer interventions and lower enquiry costs. It complements, and does not replace, the Transfer Pricing Records Regulations 2023Legislation, under which master and local files are maintained and produced on request rather than filed as standardLegislation. Around 75,000 businesses sit within the United Kingdom's transfer-pricing, permanent-establishment and foreign-permanent-establishment rulesLegislation and will need to submit informationLegislation. One-off familiarisation and systems costs plus recurring data-gathering costs fall on them, with the dataset deliberately aligned to similar overseas requirements so groups report readily available information.

Scope and detail are tiered. The Regulations set the reporting obligation, liability to a penalty for failure and a right of appealLegislation; the specifics, including which transactions and thresholds, which datapoints and which easements, sit in an HMRC notice as tertiary legislationLegislation, to be published once the Regulations are in forceLegislation, with further provision possible by general or specific direction of the Commissioners. Exemptions secured during consultation include dividends, transactions accepted as low-risk following review under the International Compliance Assurance Programme, transactions in HMRC's Advance Pricing Agreement procedure, and charities with their wholly owned trading subsidiariesLegislation; small and micro businesses are outside the measureLegislation and there is no significant public-sector impact.

The design follows a policy consultation from 28 April to 7 July 2025 and a technical consultation on the draft regulations, notice and reporting template from 16 June to 31 July 2026, which produced broader aggregation of transactions and a lighter administrative burden than earlier models. Guidance is available now at INTM917300Legislation, with detailed notice guidance due on GOV.UK by the time the requirement takes effectLegislation. Monitoring runs through continuing HMRC and Treasury engagement with industry; the instrument carries no statutory review clauseLegislation. Legal basis: section 48 of the Finance Act 2026Legislation, with international controlled transactions defined by the transfer-pricing condition in Part 4 of TIOPA 2010Legislation and the permanent-establishment condition by reference to CTA 2009Legislation.