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HMRC internal manual

Advance Tax Certainty Service

ATCS06400 - Governance and legal: what happens if legislation changes

Statutory powers within the Advance Tax Certainty regime will not be able to protect customers from changes to legislation. Legislation should be applied as the courts would apply it. Where legislation changes in a way that materially alters the tax treatment agreed in the clearance, that aspect of the clearance would cease to apply, as appropriate.