New UK Transfer Pricing Documentation Law to Cover Partnerships

December 4, 2025, 5:04 PM UTC

The UK’s new transfer pricing documentation requirements for multinationals will also apply to partnerships that are subject to corporation tax.

The detail is part of the government’s Finance Bill, introduced in Parliament Thursday after broad features were announced last week.

The measure proposes empowering His Majesty’s Revenue and Customs to issue detailed regulations for design of what is called the International Controlled Transactions Schedule, or ICTS, after more consultation with stakeholders, according to an explanatory note accompanying the bill.

The new system will require multinational enterprises to report cross-border related-party transactions annually. Transfer pricing rules govern the pricing of ...

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