Advance tax certainty service
Published 26 November 2025
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This publication is available at https://www.gov.uk/government/publications/advance-tax-certainty-service-major-investment-projects-with-certainty-in-advance/advance-tax-certainty-service
Who is likely to be affected
Taxpayers who plan to invest £1 billion or more in the UK over the lifetime of a project, and in doing so want to apply for advance certainty on its expected taxation.
General description of the measure
The government is introducing a dedicated service in HMRC to provide major investment projects with certainty on the application of tax law to their specific circumstances. This includes Corporation Tax, VAT, Stamp taxes, PAYE and operation of Construction Industry Scheme.
This measure will ensure that HMRC can provide statutory clearances as part of this service.
Policy objective
This measure contributes to the government’s objective to deliver a stable and transparent tax environment by reducing tax uncertainty for major UK investment projects. It responds to calls from industry for clarity by providing binding tax certainty for major project investments, demonstrating the government’s commitment to boosting long term economic growth in the UK.
Background to the measure
In the Corporate Tax Roadmap published at Autumn Budget 2024, the Chancellor announced a consultation on a new service from HMRC to offer ‘advance tax certainty’ to major investment projects in the UK. The original details were set out in the Corporate Tax Roadmap.
The consultation opened on 31 March and concluded on 17 June.
At Budget 2025, the government published a summary of responses to this consultation.
Detailed proposal
Operative date
The service will open in July 2026.
Current law
As a new service, there is no specific extant legislation.
Legislation will be introduced in the Finance Bill 2025-26.
Proposed revisions
Legislation will be introduced in Finance Bill 2025-26 which will give HMRC the power to issue a clearance on the application of Corporation Tax, VAT, Stamp Taxes, PAYE and operation of Construction Industry Scheme to certain project expenditure. Qualifying project expenditure must be at least £1 billion. Subject to full initial disclosure of all material facts, a clearance will bind HMRC for five years and may be renewed for a further five years — unless a material change in the law, or court decision that clarifies its application, means that the prior clearance is no longer correct.
Summary of impacts
Exchequer impact (£ million)
| 2025 to 2026 | 2026 to 2027 | 2027 to 2028 | 2028 to 2029 | 2029 to 2030 | 2030 to 2031 |
|---|---|---|---|---|---|
| nil | nil | nil | nil | nil | nil |
This measure is not expected to have an Exchequer impact.
Macroeconomic impact
This measure is not expected to have any significant macroeconomic impacts.
Impact on individuals, households and families
There is no impact on individuals as this measure only affects businesses.
Equalities impacts
This measure only affects businesses, therefore it is not anticipated there will be disproportionate impacts on those in groups sharing protected characteristics.
Administrative impact on business including civil society organisations
This measure impacts businesses who plan to invest £1 billion in the UK over the lifetime of a project and want to apply for a clearance through HMRC’s dedicated service. The certainty provided is expected to benefit these businesses.
This measure is expected to have a negligible impact on administrative burdens for businesses who apply for the service. One-off costs could include businesses needing to familiarise themselves with the changes. Continuing costs could include maintaining additional records.
This measure is expected overall to impact businesses experience of dealing with HMRC as it provides eligible customers with a clear upfront position on how it intends to apply tax rules to material aspects of an investment project.
This measure is not expected to impact civil society organisations.
Operational impact (£ million) (HMRC or other)
HMRC operational impacts for this change will result in further staff costs which are estimated to be £4.1 million over the scorecard period and may incur additional IT costs estimated to be £1.6 million.
Other impacts
Other impacts have been considered, and none have been identified.
Monitoring and evaluation
Consideration will be given to monitoring this measure through information collected from both internal stakeholders and external business feedback surveys and kept under review through a planned review period.
Further advice
If you have any questions about this change, contact HMRC by email advancetaxcertainty@hmrc.gov.uk.