The International Controlled Transaction Reporting Regulations 2026
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Change 1
4 Requirement to provide specified information
(1) Subject to regulation 5, paragraph (2) applies where within an accounting period or underwriting year the total value of a specified international controlled transaction, or specified international controlled transactions aggregated in accordance with regulation 7(3), meets the threshold requirement specified in a notice published by the Commissioners. (2) A reporting entity must— (a) on or after the date specified in a notice published by the Commissioners, and (b) on or before the submission deadline identified in regulation 6, provide the specified information in connection with all specified international controlled transactions within that accounting period or underwriting year to an officer of Revenue and Customs. (3) Where the reporting entity is a managing agent (see regulation 16(1)(c)), it must provide the specified information required by paragraph (2) with respect to each specified international controlled transaction relating to— (a) the managing agent, and (b) each member of each syndicate that it manages. (4) Where a transaction is an international controlled transaction by virtue of meeting— (a) both the transfer pricing condition and the permanent establishment condition, the— (i) reporting entity, or (ii) reporting entities where there is a different reporting entity for each condition must provide the specified information in relation to each specified international controlled transaction with respect to each condition; (b) either the transfer pricing condition or the permanent establishment condition, the reporting entity must provide the specified information with respect to that condition. (5) Information purporting to be specified information provided on behalf of a reporting entity is presumed to have been provided by that entity, unless the entity proves that the information was provided without the entity’s authority.
4 Requirement to provide specified information
(1) Subject to regulation 5, paragraph (2) applies where within an accounting period or underwriting year the total value of a specified international controlled transaction, or specified international controlled transactions aggregated in accordance with regulation 7(3), meets the threshold requirement specified in a notice published by the Commissioners. (2) A reporting entity must— (a) on or after the date specified in a notice published by the Commissioners, and (b) on or before the submission deadline identified in regulation 6, provide the specified information in connection with all specified international controlled transactions within that accounting period or underwriting year to an officer of Revenue and Customs. (3) Where the reporting entity is a managing agent (see regulation 16(1)(c)), it must provide the specified information required by paragraph (2) with respect to each specified international controlled transaction relating to— (a) the managing agent, and (b) each member of each syndicate that it manages. (4) Where a transaction is an international controlled transaction by virtue of meeting— (a) both the transfer pricing condition and the permanent establishment condition, the— (i) reporting entity, or (ii) reporting entities where there is a different reporting entity for each condition must provide the specified information in relation to each specified international controlled transaction with respect to each condition; (b) either the transfer pricing condition or the permanent establishment condition, the reporting entity must provide the specified information with respect to that condition. (5) Information purporting to be specified information provided on behalf of a reporting entity is presumed to have been provided by that entity, unless the entity proves that the information was provided without the entity’s authority.
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