Entity Setup
Navigating the New Advance Tax Certainty Service: Big Projects, Big Benefits
Aimed at major investment projects, HMRC’s new Advance Tax Certainty Service introduces binding clearances—learn who qualifies, how to apply, and how to use this tool to reduce risk.
By NomadicTax Research Team • 5-8 min read • June 16, 2026
## What is the Advance Tax Certainty Service?
The **Advance Tax Certainty Service (ATCS)** is a newly launched tool by HMRC designed to give businesses binding clarity on how UK tax rules will apply to **major investment projects** before final investment decisions are taken. ([gov.uk](https://www.gov.uk/guidance/advance-tax-certainty-service?utm_source=openai))
## Who qualifies?
- Must involve **at least £1 billion** of qualifying UK expenditure over the project’s lifetime. ([gov.uk](https://www.gov.uk/guidance/advance-tax-certainty-service?utm_source=openai))
- Can be a company or entity that controls that expenditure; joint ventures or consortia can nominate a qualifying person. ([gov.uk](https://www.gov.uk/guidance/advance-tax-certainty-service?utm_source=openai))
## What’s covered?
The service can issue clearances on how UK taxes will apply, including:
- Corporation Tax
- VAT
- Stamp Duty Land Tax
- Income Tax
- PAYE regulations
- Construction Industry Scheme
Note: **Transfer pricing is excluded**—but existing Advance Pricing Agreements remain available. ([gov.uk](https://www.gov.uk/guidance/advance-tax-certainty-service?utm_source=openai))
## Timeline & Compliance Steps
| Step | Description |
|------|-------------|
| **Launch date** | Effective **1 July 2026**, with expressions of interest accepted from **1 June 2026**. ([gov.uk](https://www.gov.uk/guidance/advance-tax-certainty-service?utm_source=openai)) |
| **Early engagement** | After expressing interest, an early meeting with HMRC will define scope and information to be supplied. |
| **Clearance submission** | Formal written request accompanied by required documentation. |
| **Decision time** | HMRC aims to issue clearances within **90 days** of complete submission. |
## Practical Example
An international energy company planning a £1.2 billion renewable infrastructure project in the UK wishes to know the VAT treatment, Stamp Duty, and whether its proposed capital expenditure qualifies for relief. Using ATCS, they apply in June, meet with HMRC in July, submit paperwork by August, and receive binding clearance by November—allowing them to proceed with investment with low tax uncertainty.
## Benefits
- **Reduced risk of unexpected tax exposure** at later stages
- **Financial planning confidence**—knowing tax inputs ahead of major spending
- **Competitive advantage** in bidding or project financing
## Considerations & Caveats
- Expenditures or facts that change may affect the clearance’s applicability.
- Clearances valid for **up to 5 years**—if the project extends, renewal or fresh application may be required. ([gov.uk](https://www.gov.uk/government/consultations/advance-tax-certainty-for-major-projects-consultation/outcome/advance-tax-certainty-for-major-projects-summary-of-response?utm_source=openai))
- Initial threshold of £1 billion limits eligibility to very large projects; expectation is this may adjust over time.
## Actionable Advice for Businesses
1. **Assess eligibility early**—if you’ve got planned big expenditures, consider ATCS vs conventional tax risk.
2. **Document everything meticulously**—you’ll need factual clarity on expenditure, timelines, tax exposures.
3. **Engage HMRC early**—take advantage of early engagement meetings.
4. **Monitor legislative developments**—draft legislation and guidance are rolling out over summer 2026.
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Category: Entity Setup
TaxHome: UK
Author: NomadicTax Research Team
ReadTime: 5-8 min
Published: true