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HMRC internal manual

Advance Tax Certainty Service

ATCS05620 - Advance Tax Certainty Service: Process: Post-issuance: Changes to facts

An applicant's ability to rely on a clearance may be impacted where either:

  • there has been a material change to the facts of an investment project from how it is set out in the clearance
  • anything set out in the clearance, and which is material to it, such as a critical assumption, is no longer accurate

If the customer is unsure whether a change is considered material, they should contact HMRC for advice. Failure to notify HMRC may mean the clearance is no longer valid, cannot be relied upon or may incur a penalty.