HMRC has issued an Advance Tax Certainty Service Manual providing guidance on eligibility, governance, and process for the new service aimed at supporting large-scale UK investment projects and reducing tax uncertainty.
The UK’s His Majesty’s Revenue and Customs (HMRC) has published an Advance Tax Certainty Service Manual on 1 June 2026 to support both taxpayers and HMRC staff in operating the new Advance Tax Certainty Service.
The manual provides structured guidance across key areas, including:
- ATCS01000 – Advance tax certainty (contents)
- ATCS02000 – Eligibility and scope (contents)
- ATCS04000 – Process (contents)
- ATCS06000 – Governance and legal (contents)
- ATCS08000 – Low-risk view on unallowable purpose rules under the loan relationships and derivative contracts regimes (contents)
The Advance Tax Certainty Service is designed to support the UK government’s objective of creating a more stable and transparent tax environment by reducing uncertainty for large-scale investment projects. It aims to encourage investment and economic growth by enabling businesses to plan and deliver major projects with greater certainty.
To qualify for the service, a project must involve at least GBP 1 billion of qualifying expenditure in the UK over its lifetime.
Earlier, HMRC published guidance on 12 May 2026 regarding the Advance Tax Certainty Service, which is scheduled to be launched on 1 July 2026.
