ATCS02100 - Advance Tax Certainty Service: Eligibility and Scope: Who may apply for a clearance?
A qualifying person may apply for a clearance. This can be the person who is incurring the project expenditure or a person who controls them. In most cases, a qualifying person will be a company.
Where no single person has overall control (such as in the case of a Joint Venture (JV)), or there are multiple interested parties (such as in the case of Consortium), one qualifying person may apply on behalf of the qualifying persons.
Both UK and non-UK resident entities investing in the UK may apply.
If the investment entity does not yet exist, a qualifying person who will control it can apply on its behalf. The clearance would be binding as regards the entity or entities named as incurring the project expenditure, and not the applicant.