Explanatory note

These Regulations make provision in connection with the provision of information in relation to international controlled transactions.

Regulation 1 provides for citation and commencement of the Regulations. It also provides for the application of the Regulations to accounting periods beginning on or after 1st January 2027 and, to underwriting years beginning on or after 1st January 2027 where the profits or losses arising to a member in any underwriting year directly from its membership of one or more syndicates are required to be declared on or after 1st January 2030.

Regulation 2 defines terms used in the Regulations.

Regulation 3 sets out the scope of a notice published by the Commissioners.

Regulation 4 sets out the requirement upon a reporting entity to provide specified information in relation to a specified international controlled transaction to an officer of Revenue and Customs, where the threshold requirement is met.

Regulation 5 provides an exception to regulation 4 and the requirement to provide specified information.

Regulation 6 sets out the submission deadline.

Regulation 7 specifies the form and manner that specified information is to be provided to an officer of Revenue and Customs.

Regulation 8 makes provision for Commissioners’ directions.

Regulation 9 sets out the requirement for information to be consistent with the analysis applied in the relevant return and to be accurate.

Regulation 10 sets out the circumstances in which a reporting entity must, or may, amend the specified information.

Regulation 11 provides an exception to the requirement to amend specified information.

Regulation 12 makes provision for the amendment procedure.

Regulation 13 sets out the amendment deadline.

Regulation 14 specifies the international controlled transactions to which the requirement to provide information applies.

Regulation 15 provides an exception to the specification of a specified international controlled transaction.

Regulation 16 specifies which entities are reporting entities which are required to provide specified information where the transfer pricing condition is met.

Regulation 17 specifies which entities are reporting entities which are required to provide specified information where the permanent establishment condition is met.

Regulation 18 specifies the description of information that is specified information.

Regulation 19 makes provision for penalties for breaches of obligations imposed by the Regulations, including provision for appeals and enforcement.

Regulation 20 makes provision for a daily default penalty to apply in the event that specified information is not provided following notice of an assessment under regulation 19.

Regulation 21 makes provision for a penalty following the provision of inaccurate specified information.

Regulation 22 sets out the matters to be disregarded in relation to the liability of a penalty.

Regulation 23 makes provision for the assessment of a penalty by an officer of Revenue and Customs and the relevant deadline for such an assessment to be carried out.

Regulation 24 makes provision for a right to appeal against a penalty.

Regulation 25 sets out the procedure on appeal against a penalty.

Regulation 26 sets out the procedure for an officer of Revenue and Customs to apply to the Tribunal for an increased daily default penalty.

Regulation 27 makes provision for the payment and enforcement of penalties.

Notices and directions made under these Regulations will be published at https://www.gov.uk/money/corporation-tax.

The ICAP Handbook for tax administrations and MNE groups can be found here: https://www.oecd.org/en/publications/2021/02/international-compliance-assurance-programme_adf0be32.html. Copies of the ICAP Handbook are available for inspection in hard copy form from 100 Parliament Street, London, SW1A 2BQ.

A Tax Information and Impact Note covering this instrument was published on 25th November 2025 alongside the Budget 2025 and is available on the website at https://www.gov.uk/government/collections/tax-information-and-impact-notes-tiins. It remains an accurate summary of the impacts that apply to this instrument.