- The government is introducing a new advance tax certainty service to provide businesses with binding certainty on how tax rules will apply to major investment projects in the UK before significant investment takes place.
- The service will be open to both UK and non-UK resident entities, and initially there will be no fee for using the service.
- Eligible projects must involve new investment in the UK and expenditure of at least £1bn over their lifetime, excluding financing costs and expenditure related to acquisition of shares and ownership interests.
- In scope taxes include corporation tax, VAT, stamp duty land tax, income tax, PAYE, and the construction industry scheme.
- The service will offer a possibility to request an early engagement discussion to check if clearance is likely before committing resources to the process.
- Clearances issued will represent a binding decision of the government’s view of the law, as applied to the fully disclosed facts, unless those facts materially change, or there is a change in relevant legislation. Clearances will not be published.
- Timing: Legislation for the service is included in Finance (No. 2) Bill 2024-26. Draft guidance on the operation of the service during its first year was published in December 2025. The service will be operational from July 2026.
Resources (click to open)
.jpg)