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Applying for HMRC non-statutory UK tax clearances: suitability, drafting, checklists, submission routes, timelines, reliance and alternatives, plus the forthcoming advance tax certainty service

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Practice notes
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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 Initially, no fees will be charged and anonymised clearance summaries will not be published.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 UK expenditure is in scope and the £1bn threshold and qualifying persons criteria are met. In addition, following the initial Autumn Budget 2024 announcement as part of the Corporate Tax Roadmap,...

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Web page updated on 21/05/2026

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