Advance tax certainty for major projects consultation
Read the full outcome
Detail of outcome
Between March and June 2025, the government consulted on the design of a new HMRC service that will provide major investment projects with certainty in advance about how tax will apply. The government took the responses received into consideration when designing the service.
The government is now publishing its response to the consultation. This document summarises the responses received, and sets out details about how the ‘Advance Tax Certainty Service’ will operate. The service will launch in July 2026.
HMRC will be publishing technical guidance alongside the Finance Bill. A link to this guidance will be added to this page.
Original consultation
Consultation description
At Autumn Budget 2024, the government announced in its Corporate Tax Roadmap that it would be consulting on a new process to provide increased tax certainty in advance for major projects.
The consultation seeks views on taxpayers’ priorities and sets out thinking on how a new process could work to support investment decisions.
Please submit responses to advancetaxcertainty@hmtreasury.gov.uk and advancetaxcertainty@hmrc.gov.uk.
This consultation also separately announces the outcome of the review of the transfer pricing treatment of Cost Contribution Arrangements (CCAs). Businesses will be able to obtain certainty on the transfer pricing treatment of such arrangements through the UK’s existing Advance Pricing Agreement programme.
The government is further supporting stability for business investment by consulting on a potential revised system of advance clearances for the Research & Development reliefs, with the aim of providing greater certainty for businesses planning to invest, while reducing error and fraud.
Documents
Updates to this page
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Outcome of consultation added.
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Accessible HTML version of document added.
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First published.