Duties of a senior accounting officer (SAO)
Duties of a senior accounting officer (SAO)

The following Tax guidance note provides comprehensive and up to date legal information covering:

  • Duties of a senior accounting officer (SAO)
  • Main duty
  • Tax accounting arrangements
  • Appropriate tax accounting arrangements
  • Reasonable steps
  • Standing data
  • Mergers and acquisitions
  • SAO certificate
  • Unqualified certificate
  • Qualified certificate
  • more

The senior accounting officer (SAO) regime was introduced by section 93 of, and Schedule 46 to, the Finance Act 2009 (FA 2009) with the aim of ensuring that qualifying companies have adequate tax accounting arrangements in place so that the correct tax liabilities are reported to HMRC. The regime applies to financial years beginning on or after 21 July 2009.

To comply with the SAO provisions, an SAO must in respect of the qualifying company or companies for which the person is the SAO:

  1. carry out the main duty during each financial year (or at least for that part of a year) for which the person is the company's SAO, and

  2. provide a certificate to HMRC after the end of each relevant financial year about the appropriateness of the tax accounting arrangements of the relevant company or companies in question

This Practice Note:

  1. details the specific duties and responsibilities that form part of an SAO's main duty to take reasonable steps to ensure that the company establishes and maintains appropriate tax accounting arrangements (ie accounting arrangements that enable the company's relevant tax liabilities to be calculated accurately in all material respects) and, as part of that, considers:

    1. the concept of 'appropriate tax accounting arrangements', and

    2. the meaning of 'accurate in all material respects', and

  2. covers the SAO's obligation to submit a certificate at

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