United Kingdom · Enacted legislation
UK clearance threshold falls to £300 million under provisional resolution
On 3 November 2026, the House of Commons approved Resolution 101 reducing the UK advance-tax-clearance project threshold from £1 billion to £300 million from 4 November, with provisional statutory effect rather than Royal Assent to a Finance Act.
- Official document:
- Commons Votes and Proceedings 3 November 2026, Resolution 101; Finance Act 2026 sections 266(2) and 270(1)
- Development date:
- 2026-11-03
A specific amendment, not just a Budget intention
The resolution substitutes £300 million in Finance Act 2026 section 266(2). It also removes applications for clearance from section 270(1)’s information provision, narrowing its scope to issued clearances. The resolution expressly commences both amendments on 4 November and contains the declaration for statutory effect under the Provisional Collection of Taxes Act 1968. The earlier Budget announcement alone did not establish this parliamentary step.[4][1]
Provisional force is not final enactment
The adopted text expressly invokes the Provisional Collection of Taxes Act 1968: its statutory-effect declaration is not Royal Assent to a Finance Act. The same proceedings record the Finance Bill’s first reading. A separate resolution authorises a future change to the regulation-making procedure; it does not itself implement the Budget’s proposed 1 April 2027 procedure change.[4][1]
Qualifying project expenditure still matters
HMRC’s public service page now states £300 million of lifetime qualifying UK expenditure. Its older ATCS02200 manual still displays £1 billion, so that figure should not override the new resolution. The manual’s expenditure explanation excludes finance costs, equity investment such as standalone acquisitions or share buybacks, and ordinary ongoing activity. It describes a new investment initiative involving UK-used goods, services and assets, rather than a group-revenue test.[2][5][4]
Prepare before requesting clearance
An applicant must be a qualifying person, such as the spender or a controlling person; joint-venture or consortium arrangements need the appropriate nominated applicant. Transfer pricing is excluded from this service and has a separate APA route. Groups should document project scope, expenditure and unresolved tax questions, and reconcile them with HMRC during early engagement. The stated 90-day response is a conditional service aim, not a taxpayer filing deadline or guaranteed acceptance.[2][3]
Official sources
- [1] Budget 2026: Overview of tax legislation and rates
HM Revenue & Customs · Document date: 2026-10-28
Section 1.41, threshold reduction, proposed Finance Bill 2026–27 amendments and intended dates. Contents and corporate-tax section screened; no complete Budget package review claimed.
- [2] Advance Tax Certainty Service
HM Revenue & Customs · Document date: 2026-10-28
Updated 28 October for qualifying expenditure; service description, eligible persons, lifetime project expenditure, taxes, process and 90-day aim. Full substantive body read.
- [3] ATCS04120: How HMRC will manage capacity in the first year
HM Revenue & Customs · Document date: 2026-06-22
Paragraphs on expressions of interest, complexity/urgency triage and potential postponement or refusal; historical framework, not a new official event.
- [4] Commons Votes and Proceedings, 3 November 2026
House of Commons · Document date: 2026-11-03
Resolutions 101 and 102, lines 1762–1776; Finance Bill first reading, lines 1820–1825. Resolution 101 expressly amends Finance Act 2026 sections 266(2) and 270(1), commences 4 November and includes provisional statutory-effect declaration. Operative text read.
- [5] ATCS02200: Financial threshold for entry
HM Revenue & Customs · Document date: 2026-06-22
Full substantive body, lines 71–83; expenditure scope and exclusions. £1 billion figure is an older unreconciled manual value, expressly not used as current threshold.