What multinational groups need to know about UK tax planning and governance in 2026

Gravita tax partners Fiona Cross and Claire Boden deliver a webinar on UK tax planning, compliance, and governance for multinational groups. Fiona covers UK transfer pricing scope and documentation, HMRC risk indicators, the replacement of diverted profits tax with the unassessed transfer pricing profits regime, and proposed International Controlled Transactions Schedule reporting from 2027. She explains Pillar Two’s 15% global minimum tax (including multinational and domestic top-up taxes and the 2026 “undertaxed profits rule” development) and the UK requirement to publish a tax strategy for large groups, including the four mandatory content areas and penalties. Claire then outlines the Senior Accounting Officer regime (thresholds, certification, and personal penalties), corporate interest restriction rules (including the £2m threshold, fixed ratio, group ratio, elections, and compliance timing), and the corporate criminal offence of failure to prevent facilitation of tax evasion, emphasizing risk assessments and reasonable prevention procedures. 00:00 Welcome and Housekeeping 00:38 Agenda and UK Tax Focus 01:01 Transfer Pricing Basics 02:33 Documentation and HMRC Red Flags 05:03 Transfer Pricing Updates and UTPP 07:56 ICTS Reporting Consultation 09:21 Pillar Two Minimum Tax 11:58 Tax Strategy Publication Rules 14:00 Senior Accounting Officer Regime 19:54 Corporate Interest Restriction Explained 25:22 Corporate Criminal Offence Rules