New UK Transfer Pricing Rules - Preparing for 2027

Introduction

The UK transfer pricing landscape is changing, with reforms to the domestic rules and the proposed International Controlled Transactions Schedule (ICTS) bringing new compliance considerations for businesses and their advisers.

Presented by Rafaela Oplopoiou-Chapman, this practical webinar will explain the key reforms, outline the anticipated ICTS reporting requirements and highlight the steps businesses should take to prepare. It will also consider how the information reported could inform HMRC’s risk assessment and future enquiries.

The webinar is designed for tax advisers, accountants, in-house tax professionals and finance teams seeking a concise overview of the changes and their practical implications.

What You Will Learn

This webinar will cover the following:

• The key UK transfer pricing reforms
• Overview of the reform package and its practical significance
• Key changes affecting UK-to-UK transactions and the participation condition
• Headline implications for financial transactions and intangibles
• Understanding the ICTS
• Why it is being introduced and which businesses and transactions are expected to fall within scope
• Anticipated materiality thresholds, exemptions and reporting requirements
• Expected implementation timetable and key compliance considerations
• HMRC risk assessment and reporting consistency
• How HMRC may use ICTS information to identify transfer pricing risk
• Potential risk indicators that could attract additional scrutiny
• Maintaining consistency between the ICTS, tax returns and transfer pricing documentation
• Preparing for the new requirements
• Mapping relevant related-party transactions and identifying gaps in available data
• Reviewing transfer pricing policies, documentation and internal controls
• Brief worked examples illustrating reporting considerations and potential risk indicators
• A practical checklist of priority actions before implementation