Introduction to senior accounting officer (SAO) requirements
Introduction to senior accounting officer (SAO) requirements

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

  • Introduction to senior accounting officer (SAO) requirements
  • Qualifying companies
  • What is a group for the SAO rules?
  • Taxes covered by the SAO regime
  • Who is the SAO?
  • Notification of SAO details to HMRC
  • The role of the SAO
  • SAO time limits
  • Penalties

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. The aim of the regime is supported by:

  1. a qualifying company's obligation to notify HMRC of the identity of its SAO or, if there were successive SAOs for the relevant financial year, each individual that was the SAO for any part of that year

  2. the role of the SAO to take reasonable steps to ensure that the qualifying company has appropriate tax accounting arrangements in place

  3. the SAO's obligation to file a certificate for each financial year confirming that the company had appropriate tax accounting arrangements or, where that was not the case, explaining the deficiencies and (although not legally required) often also includes what steps are being taken to remedy them, and

  4. HMRC's authority to assess penalties on a qualifying company and/or an SAO for failing to satisfy the SAO rules

The regime was brought in to complement and reinforce HMRC's risk assessment approach to large businesses with the aim of:

  1. ensuring that such companies have and maintain adequate tax accounting

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