Advance Tax Certainty Service

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.

The Advance Tax Certainty Service launched on 1 July 2026.

Make an expression of interest to [email protected] or your Customer Compliance Manager (CCM).

Meet HMRC for an early engagement meeting.

Submit your clearance request in writing.

Meet with HMRC to agree on the scope of what needs to be covered.

HMRC then reviews your clearance request.

If your clearance request is accepted, HMRC issues a binding clearance.

To apply, your project must have at least £300 million 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.

Under this service, the clearance can cover uncertainties relating to the following UK taxes:

The service will not cover transfer pricing, but where appropriate the existing Advance Pricing Agreement programme is available on GOV.UK.