- At the Spring Statement 2025, the government launched a consultation on the development of a new process giving major investment projects increased tax certainty in advance, as previously signposted in the Corporate Tax Roadmap.
- The proposal is for a dedicated service which provides statutory certainty over how the tax rules will be applied to an investment project if it proceeds as planned. The focus of the clearance service will be corporation tax, although the consultation asks whether there would be a benefit for other taxes, such as VAT and stamp taxes.
- The service would be open to companies that currently are, or will be in future, subject to UK Corporation Tax. The service will be relevant for the largest major investment projects and the government expects that ‘dozens’ of projects would be eligible each year, with each project likely to entail qualifying expenditure in the ‘hundreds of millions’. Smaller investment projects may be included if they are considered to be of national or strategic importance.
- Areas under consultation include eligibility, whether applicants should be charged for using the service, and the possibility of publishing summarised and anonymised clearances. Unlike some of the existing clearance processes, the new service will not require the demonstration by the business of 'genuine uncertainty'.
- The clearance process would include key steps, including a written application, a scoping meeting and a decision, as well as an optional pre-application meeting. The timeline for the decision process is anticipated to take 60 days from the initial application date.
- Timing: the consultation closes on 17 June 2025. The government intends for the new process to be implemented in 2026.
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