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FORTHCOMING CHANGE relating to new advance clearance processes: Following an initial announcement at Autumn Budget 2024 under the government’s Corporate Tax Roadmap, and a consultation released alongside Spring Statement 2025, Budget 2025 set out the consultation outcome and confirmed HMRC will introduce an advance tax certainty service in July 2026. The regime is intended for qualifying persons backing ‘major projects’ with at least £1bn of eligible UK spend. As trailed at Budget 2025, the service will address a defined suite of taxes—corporation tax, VAT and stamp taxes—while excluding transfer pricing, valuation, purpose‑based tests and hypothetical cases. Clearances will commit HMRC (but not the taxpayer) not to revise its view of the law, on the basis of fully disclosed facts, for up to five years, provided facts and law remain unchanged, with pragmatic renewal available. Initially, no fees will be charged and anonymised clearance summaries will not be published. Enabling legislation was included in Finance Bill 2026. Draft technical guidance was issued on 10 December 2025. The service applies where...
FORTHCOMING CHANGE relating to new advance clearance processes: After first being trailed in the Autumn Budget 2024 within the government’s Corporate Tax Roadmap, and then consulted on at the Spring Statement 2025, the Budget 2025 set out the consultation conclusions and confirmed HMRC will roll out a new advance tax certainty service in July 2026. This service is intended for eligible parties investing in ‘major projects’ with at least £1bn of in-scope UK spend, aimed at qualifying persons. The Budget 2025 announcements indicated that the service will cover a specified range of taxes, including corporation tax, VAT and stamp taxes, but will exclude transfer pricing, valuation, purpose-based tests and hypothetical cases. Clearances will bind HMRC (but not the taxpayer) from revising its interpretation of the law, applied to fully disclosed facts, for up to five years, provided facts and law are unchanged, with pragmatic renewal thereafter. Initially, no fees will be charged and anonymised clearances will not be published. Enabling legislation was included in Finance Bill 2026. Draft technical...
This Practice Note outlines the principal UK government support available across 2022–25 for households and non-domestic users—such as businesses, charities and public sector bodies—designed to help them handle exceptionally high energy costs following the 2022 energy price crisis. Why did the UK government need to provide exceptional energy bills support? Global energy price shocks, intensified by the Russian invasion of Ukraine on 24 February 2022, drove wholesale prices markedly higher in the second half of 2022. There was broad concern about the consequences for domestic and non-domestic consumers, many of whom feared bills would become unaffordable, with serious implications for the wider economy. In response, the then Prime Minister, Liz Truss, stated on 8 September 2022 that emergency legislation would be introduced to help customers manage their energy costs over the winter. More broadly, the government has undertaken, and continues to pursue, reform of the retail energy market, with fair pricing for consumers as a key objective. For more information, see Practice Note: Retail Energy Market Reform in...