UK HMRC opens consultations on transfer pricing with proposals for SME exemption, ICTS and broader TP reform

01 May 2025|Tax Alerts, Information Reporting, National/Federal Taxation, Transfer Pricing, Global|United Kingdom

On 28 April 2025, HMRC launched a 10-week consultation proposing the removal of the transfer pricing (TP) exemption for medium-sized enterprises and the introduction of an International Controlled Transactions Schedule (ICTS), effective for fiscal years beginning as early as 2026-27.
The proposed changes would require medium-sized groups and large businesses to implement arm's-length pricing for all cross-border transactions and prepare contemporaneous TP documentation, increasing compliance obli…

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