UK Transfer Pricing Data Push to Drive HMRC Queries, Revenue

Multinationals in the UK are bracing for a wave of targeted inquiries projected to increase transfer pricing revenue after the advent of a new documentation requirement.

The government’s International Controlled Transactions Schedule, or ICTS, set to launch in 2027, will provide His Majesty’s Revenue and Customs with standardized data that could enable cross-industry comparisons and prompt more targeted inquiries into multinationals, tax professionals say.

Through ICTS, HMRC will be more “working smarter than working harder,” said Sarah Ling, a tax partner at Macfarlanes. The schedule will give the tax authority standardized, transaction-level data from ...