HMRC Advance Tax Certainty Service Live: £1bn Projects Get Binding Clearance

HM Revenue & Customs launched the Advance Tax Certainty Service on 1 July 2026, giving eligible businesses a route to binding clearance on how UK tax rules apply to a major investment project before the final investment decision and through to the relevant tax return. Agent Update issue 145 highlighted the launch for agents advising large capital projects.

The service sits alongside existing clearance and Advance Pricing Agreement routes. It is aimed at major investment — not day-to-day SME Corporation Tax queries — but finance and tax leads at growing groups should know the eligibility bar and which taxes are in scope when boards discuss nine-figure UK capex.

To apply, a project must have at least £1 billion of qualifying expenditure in the UK over its lifetime. The applicant must be a qualifying person — typically the company incurring the expenditure or a person who controls it. Where no single person has overall control (for example a joint venture or consortium), one nominated qualifying person can apply on behalf of the others.

Clearances can cover uncertainties relating to Corporation Tax, VAT, Stamp Duty Land Tax, Income Tax, PAYE regulations, and the Construction Industry Scheme. Transfer pricing is out of scope of this service; HMRC points applicants to the existing Advance Pricing Agreement programme where appropriate.

HMRC’s GOV.UK guidance sets a staged journey: express interest to [email protected] or your Customer Compliance Manager; attend an early engagement meeting; submit a written clearance request; agree scope with HMRC; then receive a review and, if accepted, a binding clearance.

HMRC aims to issue a clearance within 90 days of a complete formal submission, depending on complexity and discussion with the applicant. Agent Update 145 notes that clearances are binding for five years (subject to changes in facts and law), with opportunities to renew and extend on longer-term projects. The government plans to evaluate the service after 12 months, including whether to lower the £1 billion threshold.

Treat the service as a project-governance tool: map tax uncertainties early (capital allowances, VAT recovery on construction, SDLT on land assemblies, PAYE/CIS on contractor models) and assemble a disclosure pack that matches HMRC’s eligibility and scope guidance before you express interest.

Do not assume every uncertainty is clearable — read HMRC’s Advance Tax Certainty Service manual for exclusions and evidence expectations. Smaller groups below the threshold should continue using standard clearances, non-statutory clearances where available, and adviser opinions rather than waiting for a possible future threshold cut.

FinnAccountings helps UK and Irish finance teams organise bookkeeping and tax prep drafts with Chartered Accountant insight before you or your qualified adviser engages HMRC or Revenue. Start a free trial if you need review-ready working papers for investment-case tax analyses — we do not file clearances or returns with HMRC on your behalf.

For related UK corporate context, see our Finance Bill 2026–27 Legislation Day briefing and the free tax calculator for illustrative estimates only.