About

This roundtable discussion focuses on changes in UK transfer pricing legislation affecting large groups, including the introduction of UK-UK exemption, guarantee fee provision and implicit support provision as well as the introduction of the mandatory International Controlled Transactions Schedule (ICTS) which comes into effect for UK taxpayers for accounting periods from 1st January 2027. The ICTS requires groups in-scope to disclose specifics around transaction values, counter-parties and transfer pricing methods used and will support HMRC's automated, data-led risk assessments.

The meeting will help attendees consider their preparations for the new ICTS submission requirement and whether changes to existing transfer pricing models are required in response to the new legislation, especially in the context of increasing scrutiny by HMRC.