The UK's new Advance Tax Certainty Service will provide binding tax clearances for investment projects worth at least GBP 1 billion, with HMRC aiming to issue decisions within 90 days of receiving complete applications when the scheme launches on 1 July 2026.
The UK tax authority, His Majesty’s Revenue and Customs (HMRC) has published guidance on 12 May 2026 regarding the Advance Tax Certainty Service, which is scheduled to be launched on 1 July 2026.
The Advance Tax Certainty Service is designed to support the government’s objective of creating a stable and transparent tax environment by reducing uncertainty for major investment projects in the UK. It aims to encourage investment and economic growth by helping businesses plan and deliver their objectives with greater confidence.
The service will provide businesses with a binding clearance on how tax rules will apply to a significant investment project, covering the period from before the final investment decision is made through to the filing of the relevant tax return.
Under the scheme, clearances may be sought on uncertainties relating to UK tax matters, including Corporation Tax, VAT, Stamp Duty Land Tax, Income Tax, PAYE regulations, and the Construction Industry Scheme.
The service does not apply to projects that fall within transfer pricing rules, as these are covered under the existing Advance Pricing Agreement programme.
To be eligible for the service, a project must involve at least GBP 1 billion of qualifying expenditure in the UK over its lifetime.
The application must be made by a qualifying person, typically the entity incurring the expenditure or the party exercising control over the project, which in most cases will be a company. Where control is shared, or no single party has overall control—such as in a joint venture—or where multiple qualifying persons exist, such as in a consortium, a nominated qualifying person may apply on behalf of the others.
Applicants are encouraged to be fully prepared from the outset to make effective use of the Advance Tax Certainty Service. An early engagement meeting may be arranged to discuss the project and any tax uncertainties before the formal submission of an application.
His Majesty’s Revenue and Customs aims to issue a clearance within 90 days of receiving a complete application. However, the timeframe will depend on the complexity of the case and will be subject to agreement with the applicant.
