Cross‑Border Tax Forecast 2026 in United Kingdom

Expected to launch July 2026.

The Advance Tax Certainty Service will enable taxpayers to obtain confirmation from the UK tax authority (HMRC) of the application of certain tax rules to their project. It is confirmed that projects must meet a GBP 1 billion (approx. EUR 1.15 billion) lifetime in-scope spend threshold, assessed on UK project expenditure excluding financing costs and acquisitions of ownership interests.

Both UK and non-UK resident entities can apply for the service, and clearances can accommodate entities not yet incorporated. 

The service is significantly wider than existing clearance services, so will be very beneficial for taxpayers commencing large in-scope projects looking to gain UK tax certainty.

Businesses commencing projects which will meet the GBP 1 billion (approx. EUR 1.15 billion) threshold should consider making use of the service, to obtain tax certainty from HMRC on a number of UK taxes and tax regimes.