UK Transfer Pricing Reforms - Preparing for the New Rules

Introduction

The UK transfer pricing landscape is undergoing significant change, with reforms to the domestic transfer pricing rules and the introduction of the International Controlled Transactions Schedule (ICTS) changing both the compliance burden and HMRC's ability to identify transfer pricing risk.

With the ICTS expected to apply for accounting periods beginning on or after 1 January 2027, businesses need to understand not only what they may be required to report, but how the information submitted could affect HMRC's approach to risk assessment and future enquiries.

Presented by expert speaker Rafaela Oplopoiou-Chapman, this practical live and interactive session will examine the latest UK reforms and explain what they mean in practice for businesses and their advisers.

It is designed for tax advisers, accountants, in-house tax professionals and finance teams who need to understand the changing UK transfer pricing compliance environment.

What You Will Learn

This live and interactive session will cover the following:

• The changing UK transfer pricing landscape
• Overview of the UK transfer pricing reform package
• What has changed and what remains unchanged
• Changes affecting UK-to-UK transactions
• Participation condition and other legislative changes
• Financial transactions and intangibles
• Interaction with the wider international tax framework
• The International Controlled Transactions Schedule (ICTS)
• Why the ICTS is being introduced
• Which businesses and transactions are expected to be within scope
• Materiality thresholds and exemptions
• Information that businesses will need to report
• Reporting cross-border related-party transactions
• Timing and implementation from 2027
• Penalties and compliance considerations
• HMRC's new approach to transfer pricing risk
• How HMRC intends to use ICTS information
• Automated and data-led risk assessment
• What could trigger additional HMRC scrutiny
• Ensuring consistency between the ICTS, tax returns and transfer pricing documentation
• Identifying potential risk areas before submission
• Preparing for the new regime
• Reviewing existing related-party transactions
• Assessing data availability and systems
• Aligning finance, tax and transfer pricing information
• Reviewing transfer pricing policies and documentation
• Establishing appropriate internal controls
• Practical implementation checklist
• Practical case study
• Identifying reportable transactions
• Reviewing information for an ICTS submission
• Spotting potential HMRC risk indicators
• Actions to take before the new reporting regime begins

Recording of live sessions: Soon after the Learn Live session has taken place you will be able to go back and access the recording - should you wish to revisit the material discussed.