Advance Tax Certainty Service
Get certainty on how UK tax rules will apply to a major investment project before investment takes place.
What the Advance Tax Certainty Service is
The government’s objective is to deliver a stable and transparent tax environment by reducing tax uncertainty for major UK investment projects.
The Advance Tax Certainty Service contributes to this objective and in doing so aims to boost investment and UK economic growth, whilst supporting businesses to achieve their goals.
The new Advance Tax Certainty Service will provide businesses with a binding clearance on how the tax rules will apply to a major investment project from before the final investment decision is taken up until the relevant tax return is made.
When the service is launching
The Advance Tax Certainty Service will launch on 1 July 2026 and with expressions of interest accepted from 1 June.
How it works
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Make an expression of interest to advancetaxcertainty@hmrc.gov.uk or your Customer Compliance Manager (CCM).
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Meet HMRC for an early engagement meeting.
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Submit your clearance request in writing.
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Meet with HMRC to agree on the scope of what needs to be covered.
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HMRC then reviews your clearance request.
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If your clearance request is accepted, HMRC issues a binding clearance.
Check if you’re eligible
To apply, your project must have at least £1 billion of qualifying expenditure in the UK over its lifetime.
You must be a qualifying person to apply for a clearance. This can be the person who is incurring the project expenditure or a person who controls it. In most cases, a qualifying person will be a company.
Where no single person has overall control (such as in the case of a joint venture), or there are multiple qualifying persons (such as a consortium), one nominated qualifying person can apply on behalf of the others.
You can find detail on what you need to provide in the guidance.
Which taxes are in scope of a clearance
Under this service, the clearance can cover uncertainties relating to the following UK taxes:
- Corporation Tax
- VAT
- Stamp Duty Land Tax
- Income Tax
- PAYE regulations
- Construction Industry Scheme
The service will not cover transfer pricing, but where appropriate the existing Advance Pricing Agreement programme is available on GOV.UK.
How long it takes
To get the most from the Advance Tax Certainty Service, it’s important that applicants come prepared from the start. There will be an opportunity to have an early engagement meeting to discuss the project and tax uncertainties before submitting a formal application.
HMRC aims to provide a clearance within 90 days of receiving your formal submission. This will depend on the complexity of the case and be subject to discussion and agreement with you.
Guidance
Applicants should refer to the guidance to ensure they understand the scope of what a clearance can cover as part of this service.
If you need help
If the guidance is unable to answer your query, please email advancetaxcertainty@hmrc.gov.uk.
Related content
Advance tax certainty service: draft guidance