HMRC has introduced a new Advance Tax Certainty Service designed to provide large businesses with early, binding clarity on the UK tax treatment of major investment projects.
The service forms part of the government’s wider objective to reduce tax uncertainty, support inward investment, and promote economic growth.
The service will be available from 1 July 2026, with expressions of interest open from 1 June 2026.
Who can use the service?
Access is limited to businesses undertaking major UK investment projects that meet strict eligibility criteria.
- The project must involve at least £1 billion of qualifying UK expenditure over its lifetime.
- The application must be made by a “qualifying person”, typically:
- the entity incurring the expenditure
- an entity that controls the project.
In more complex structures, joint ventures or consortiums can apply via a single nominated entity acting on behalf of the wider group.
Why would businesses use the service?
For qualifying projects, the service offers a significant opportunity to de-risk major investment decisions by securing upfront tax certainty. This may be particularly valuable for complex, capital-intensive projects where tax treatment could materially affect commercial viability.
Businesses can obtain a binding HMRC clearance confirming how tax rules will apply to a project. This certainty can be secured before the final investment decision is taken and through to the filing of the relevant tax returns.
Clearances can cover uncertainties relating to:
- Corporation Tax
- VAT
- Stamp Duty Land Tax
- Income Tax
- PAYE
- Construction Industry Scheme.
The service doesn’t cover Transfer Pricing, but where appropriate, the Advance Pricing Agreement programme is available.
What is the process?
The process is designed to be collaborative and encourages early engagement with HMRC, which aims to issue clearances within 90 days of receiving a complete formal application, although this will depend on the complexity of the project and the quality of the submission.
Taxpayers will be expected to make an expression of interest in using the service via email or to their Customer Compliance Manager (CCM) and will broadly follow the process set out below:
- Expression of interest: Submit via HMRC email or through your Customer Compliance Manager (CCM).
- Early engagement meeting: Initial discussion with HMRC to outline the project and key tax uncertainties.
- Formal clearance application: A detailed written submission setting out the technical issues.
- Scope agreement: Agreement with HMRC on the specific issues to be covered.
- HMRC review: Detailed assessment of the application.
- Binding clearance issued: Where accepted, HMRC provides a formal, binding position.
What are the key considerations for businesses?
Businesses wishing to access the service should consider the following:
- confirm that the £1 billion threshold (UK expenditure over the life of the project) will be met
- identify the appropriate applicant entity within any group or JV structure
- prepare robust technical analysis and supporting documentation
- clearly define areas of tax uncertainty requiring clearance
- engage proactively with HMRC to agree on the scope and expectations.
To discuss the new service and how best to prepare an application, please get in touch with your usual Crowe contact.
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