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 obligations for affected businesses.The consultations also aim to reform UK TP law, align permanent establishment (PE) rules with the OECD definition, bring Diverted Profits Tax (DPT) within the scope of UK corporation tax and enhance HMRC's...