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An overview by Unity Advisory, Taxand UK
His Majesty’s Revenue and Customs (HMRC) recently opened its consultation to introduce the International Controlled Transactions Schedule, a new annual filing requirement for multinational groups in scope of UK transfer pricing rules. The regime will take effect for accounting periods beginning on or after 1 January 2027.
Traditionally, master and local files have been narrative-led documents, not designed for large-scale analysis. The new International Controlled Transactions Schedule introduces standardised, structured data that can be analysed at scale using automated tools, including large language models.
Tax experts from our UK member firm, Unity Advisory, provide an overview of what the International Controlled Transactions Schedule means for UK businesses and how to prepare.
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