Jun 30

2026

Getting ready for HMRC’s new advance tax certainty service launching in July

HMRC’s new Advance Tax Certainty Service launches on 1 July 2026, giving major UK investment projects a clearer view of how tax rules will apply before the final investment decision is made. Expressions of interest opened on 1 June 2026, so large projects are already able to start early engagement with HMRC.

The service is not for every business. To qualify, a project must involve at least £1 billion of qualifying UK expenditure over its lifetime. For most owner-managed companies and SMEs, the honest position is simple: you probably will not qualify directly. Even so, the service still matters, because it shows where HMRC is putting its effort on early certainty, investment decisions and better prepared tax filings.

The idea fits the same careful planning we describe in our piece on why integration matters in financial planning.

What the service actually does

For a qualifying project, HMRC can issue a binding clearance on specified tax issues before the relevant tax return is made. It is not open-ended tax advice. It is HMRC’s view on how UK tax law applies to the facts and assumptions you have fully disclosed.

The process is collaborative. You express interest through your Customer Compliance Manager or HMRC’s dedicated mailbox, hold an early engagement meeting, agree the scope, then submit a formal clearance request. That disciplined approach is similar to the planning needed in mergers and acquisitions work, where certainty before signing can change the decision.

Who qualifies

The £1 billion threshold is measured over the lifetime of the project. HMRC says qualifying expenditure is UK expenditure on the project, excluding items such as financing costs and spending on equity investment. The project must be a new investment, not the ordinary continuation of day-to-day business activity.

Any eligible UK or overseas entity investing in a major UK project may be able to apply. Joint ventures and consortia can use a nominated qualifying person. That makes the service relevant to overseas investors putting money into Britain, which links closely to the questions we cover in tax planning for cross-border investment.

Confirming the threshold, the applicant entity and the exact tax points is the sort of groundwork that good due diligence should settle early.

The catch

A clearance is not a guarantee for all time. HMRC can only be bound while the facts and assumptions are true, there has been no relevant change in legislation or binding case law, and the business follows the treatment set out in the clearance.

The service also has limits. It does not cover transfer pricing, asset valuations, devolved taxes such as Welsh Land Transaction Tax or Scottish Land and Buildings Transaction Tax, speculative transactions, avoidance arrangements or areas where another existing clearance route is more suitable.

That means the documentation behind your application needs to be solid. Strong audit and reporting habits matter. If facts are later disputed, our forensic accounting and disputes team can help you stand behind the position you submitted.

What it means if you are not a billion-pound investor

Most businesses will not apply directly, but many may still feel the effect. Picture a UK manufacturer supplying a new £2 billion battery plant. The supplier will not file the clearance, but the developer’s VAT, PAYE or Construction Industry Scheme certainty may shape the contracts, invoices and deductions that flow down the supply chain. That is why VAT compliance across the UK and Ireland border still pays attention to major UK investment projects.

There are 2 further reasons to watch the service. HMRC will review it after its first year, including whether the threshold should be lowered. For smaller firms wanting their own certainty, the more realistic routes remain the existing non-statutory clearance process or, for eligible SMEs, the targeted R&D advance assurance pilot, which has a 40-day response aim. Our note on how tax accountants help small businesses explains how to use the right route.

How to prepare

If a major UK project might be in your future, confirm whether the £1 billion lifetime spend test is realistically met. Identify the right applicant entity within any group or joint venture. Pin down the specific tax uncertainties you want covered, rather than asking broadly. Engage HMRC early, because the service rewards open, well-evidenced submissions.

For Irish and Northern Irish readers, this is an HMRC service, so it applies to UK investment, including projects in Northern Ireland. An Irish business investing at scale in Britain may use it, while Irish-side certainty comes through Revenue’s own processes. Our cross-border tax advisory team can map both, and if a project runs into financial strain, our recovery and restructuring team can step in.

You can read the full detail on GOV.UK’s advance tax certainty service page.

Frequently asked questions

Who can use the Advance Tax Certainty Service?

A qualifying person involved in a UK project with at least £1 billion of qualifying UK expenditure over its lifetime.

Is the clearance binding?

Yes, but only on the facts, assumptions and law set out in the clearance. It can be affected by changes in law, case law or project facts.

What taxes does it cover?

It covers Corporation Tax, VAT, Stamp Duty Land Tax, Income Tax, PAYE regulations and the Construction Industry Scheme.

Is there an option for smaller businesses?

Yes. Smaller businesses may use existing non-statutory clearances or, where relevant, targeted R&D advance assurance.

Talk to us before you commit to a major project

If a large UK investment is on your horizon, or you supply one, get your tax position clear before the spending starts. SCC’s Accountants can assess whether the service fits, prepare a strong application and handle the certainty routes that suit smaller projects too. Get in touch to talk it through.