UK publishes annual international controlled-transactions reporting rules

The International Controlled Transaction Reporting Regulations 2026 come into force on 26 November 2026 and implement the reporting power in section 48 of the Finance Act 2026. They apply to accounting periods beginning on or after 1 January 2027 and to specified Lloyd's underwriting years. The instrument establishes the legal framework but leaves the transaction-value threshold and some required information to separate HMRC Commissioners' notices.^[1][4]

Cross-border transfer-pricing and permanent-establishment scope

The schedule reaches international controlled transactions meeting the transfer-pricing condition and specified dealings treated as occurring between a permanent establishment and the rest of its enterprise for UK profit attribution or exemption adjustments. Regulation 15 provides exceptions. Reporting entities can include UK-resident companies, non-UK resident companies in specified UK corporation-tax cases, partnership representative partners and Lloyd's managing agents, depending on the transaction and statutory conditions.^[3]

Threshold and reporting consequences

A threshold based on transaction value will determine whether reporting is required, but the amount must be set by Commissioners' notice. Once the threshold is met, the entity must report information on all its specified international controlled transactions for the period, not only transactions that individually exceed the threshold. Businesses should therefore build a complete transaction inventory before threshold testing.^[2]

Deadline framework

For ordinary reporting entities, the deadline for periods ending on or before 30 September 2027 is the later of 30 September 2028 and a date set by notice; for later period ends, the schedule is due with the corresponding company or partnership return. Separate rules apply to managing agents. Groups should identify the reporting entity, map related-party and permanent-establishment dealings, establish data ownership and monitor the notices for the threshold, data fields, filing start and procedure before finalising systems.^[2][3]