# The International Controlled Transaction Reporting Regulations 2026, Regulation 16: Specification of a reporting entity where a transaction meets the transfer pricing condition


(1) Where, within an accounting period or underwriting year a transaction meets the transfer pricing condition, the reporting entity is the—
(a) UK resident company in a case falling within section 48(4)(c)(i) of the FA 2026 except where regulation 16(1)(c) applies;
(b) non-UK resident company in a case falling within section 48(4)(c)(ii) of the FA 2026;
(c) managing agent of the syndicate where a person falls within section 48(4)(c)(i) or (iii) of the FA 2026 and—
(i) the person is a member, or managing agent, of a syndicate, and
(ii) the transaction is relevant to the determination of syndicate profits included in the syndicate return for the underwriting year;
(d) representative partner where a person is a partnership falling within section 48(4)(c)(iii) of the FA 2026.
(2) Where paragraph (1)(b) applies, a non-UK resident company is a reporting entity only in respect of those transactions that are relevant to the determination of the charge to corporation tax under section 5(2)(a), (c), or (d), of the CTA 2009.

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Source: https://www.legislation.gov.uk/uksi/2026/1156/regulation/16 (the official version)
Page: https://openlegislation.uk/international-controlled-transaction-reporting-regulations-2026/regulation-16
Contains public sector information licensed under the Open Government Licence v3.0. Source: legislation.gov.uk, The National Archives.