The Chancellor of the Exchequer announced that the government launched a consultation on a proposed new service aimed at providing advance statutory certainty on the application of UK corporation tax rules for businesses undertaking the “very largest and most innovative investment projects” after delivering the Spring Statement to Parliament on 26 March 2025.
At Autumn Budget 2024, the government announced in its Corporate Tax Roadmap that it would be consulting on a new process to provide increased tax certainty in advance for major projects.
This new service, set to begin in 2026, would differ from HMRC’s existing non-statutory clearance process by not requiring taxpayers to prove genuine uncertainty.
The consultation also separately announced the outcome of the review of the transfer pricing treatment of Cost Contribution Arrangements (CCAs). Businesses will be able to obtain certainty on the transfer pricing treatment of such arrangements through the UK’s existing Advance Pricing Agreement programme.
The government is further supporting stability for business investment by consulting on a potential revised system of advance clearances for the Research & Development reliefs, with the aim of providing greater certainty for businesses planning to invest, while reducing error and fraud.
