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HMRC internal manual

Advance Tax Certainty Service

ATCS05540 - Advance Tax Certainty Service: Process: Post-issuance: Legal developments post-issuance

To ensure a clearance remains valid and reliable, it is important that the applicant reaches out to HMRC to discuss any changes in law that could materially impact the clearance at the earliest practicable opportunity.

Where such changes occur, or if there is uncertainty regarding whether a change is considered material, the customer should notify the Advance Tax Certainty Team immediately for further advice and guidance. HMRC can then work with the customer to provide confirmation of ongoing clearance validity where applicable and reduce the risk of a customer relying on an invalid clearance or having a penalty of £5,000 applied.