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HMRC internal manual

Advance Tax Certainty Service

ATCS05580 - Advance Tax Certainty Service: Process: Post-issuance: When a clearance may be modified

Clearances are issued based on the facts (including accounting treatment) and legal context provided at the time of application.

Where there is a material change to the facts on which the clearance was based, or to the relevant legislation or its interpretation by the courts (case law), the clearance may no longer be valid or binding. In such cases, the applicant must notify HMRC. The applicant will have the opportunity to make representations as whether or to what extent the clearance should be modified.