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HMRC internal manual

Advance Tax Certainty Service

ATCS04180 - Advance Tax Certainty Service: Process: Early engagement and clearance applications: Content of clearance applications to HMRC

Clearance applications should include a cover letter outlining the following:

  • the basis on which the customer considers that they have met the eligibility criteria and that the exclusion criteria do not apply
  • written confirmation that the subject matter of the clearance sought has not been previously considered, or declined to be considered by HMRC (such as a non-statutory clearance, real time working, earlier enquiry or previous Advance Tax Certainty Service submission)
  • a definition of the project scope (the business or objective boundary of the project used)
  • written confirmation that any actions asked of the customer at the early engagement meeting with regard the application have been performed
  • the commitment status of the project (e.g. whether it has commenced or will do so imminently, whether spend has been authorised by the board, whether financing is in place)
  • any key timing considerations or market or commercial sensitivities HMRC should be aware of