ATCS05040 | Advance Tax Certainty Service: Process: Issuance: Clearance format and contents

Clearances will include the following core elements:

• basic information (customer details, reference number, and date of issue)

• matter(s) to which the clearance relates (summary of the issue(s) and scope)

• HMRC's position (confirmation of agreement or disagreement with the proposed tax treatment)

• key facts, assumptions and conditions

• duration and time-bound validity (typically up to 5 years, with conditions for renewal)

• monitoring and reporting (any annual reporting obligations or triggers for review)

• reliance and limitations (statement of binding effect and disclaimer(s))

• any market or commercial sensitivity flags

• confirmation governance checks have been completed

Clearances will not include tax advice or recommendations on how to structure transactions.