Businesses undertaking major UK investment projects can now apply for binding tax clearances, with HMRC aiming to issue decisions within 90 days of a formal application.
UK’s HM Revenue and Customs (HMRC) has officially launched the Advance Tax Certainty Service, with applications open since 1 July 2026 to provide binding tax clearances for eligible major investment projects.
The service is intended to reduce tax uncertainty for large-scale investments by allowing businesses to obtain certainty on how UK tax rules will apply before a final investment decision is made and up to the filing of the relevant tax return. The government said the initiative is designed to support investment, provide a more stable and transparent tax environment, and contribute to UK economic growth.
To qualify, a project must involve at least GBP1 billion of qualifying expenditure in the UK over its lifetime. Applications can be made by a qualifying person, typically the company incurring or controlling the project expenditure. For joint ventures or consortiums, one nominated qualifying person may apply on behalf of the other participants.
The clearance process begins with an expression of interest submitted either by email or through a Customer Compliance Manager (CCM). Applicants will then have an early engagement meeting with HMRC before submitting a formal written clearance request. HMRC and the applicant will agree the scope of the issues to be covered before the department reviews the application and, where appropriate, issues a binding clearance.
HMRC said it aims to provide a clearance within 90 days of receiving a formal submission, although the timeframe will depend on the complexity of the case and discussions with the applicant. Once issued, a clearance will generally remain binding for five years, subject to any changes in the underlying facts or legislation.
The service can provide certainty on issues relating to Corporation Tax, VAT, Stamp Duty Land Tax, Income Tax, PAYE regulations, and the Construction Industry Scheme. Transfer pricing is excluded from the service, with businesses instead directed to the existing Advance Pricing Agreement programme where appropriate.
HMRC has published a dedicated website and guidance manual setting out the eligibility requirements, application process and the information applicants must provide.
Earlier, HMRC 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.
