Includes announcement that APAs will be available for cost contribution agreements. Consultation closes June 17, 2025.
Following delivery of the Spring Statement by the Chancellor of the Exchequer to Parliament on March 26, 2025, the government announced a consultation on a new dedicated service for businesses investing in the “very largest and most innovative investment projects” to obtain advance statutory certainty of application of the UK corporation tax rules to be implemented in 2026.
Unlike HMRC’s current non-statutory clearance service, there would be no requirement for the taxpayer to demonstrate genuine uncertainty, and the service would be integrated with services delivered by other government departments in supporting investment in large investment projects. The clearances also could be published in an anonymized form to help taxpayers more widely understand HMRC’s technical positions.
The government also announced in the consultation that it separately intends to offer clearance on the treatment of cost contribution agreements (CCAs) through the existing legislation on advance pricing agreements (APAs).
The consultation closes on June 17, 2025.
Read an April 2025 report prepared by the KPMG member firm in the UK
For an overview of the Spring Statement and other consultations announced following delivery of the Spring Statement, read an April 2025 report prepared by the KPMG member firm in the UK.