Duties of an SAO

By Tolley in association with Philip Rutherford

The following Corporation Tax guidance note by Tolley in association with Philip Rutherford provides comprehensive and up to date tax information covering:

  • Duties of an SAO
  • Introduction
  • Tax accounting arrangements
  • Reasonable steps
  • Certificate
  • Materiality
  • Standing data and opening balances
  • VAT representative companies
  • Mergers and acquisitions


The key provisions governing the SAO regime are set out in Finance Act 2009, Schedule 46. It is the personal responsibility of the SAO, and in fact their main duty, to make sure that the company takes reasonable steps (see below) to establish, maintain and monitor the adequacy of their tax accounting arrangements to ensure the production of accurate tax returns and provide a certificate to HMRC after the end of the financial year. They must also identify any areas that do not meet the requirements and disclose these failures to HMRC as part of a certification process. See the Introduction to SAO requirements guidance note for more details on the taxes covered by the regime and the relevant administrative provisions.

The SAO must carry out their duties on an on-going basis. As the certificate covers the systems, processes and controls in place throughout the financial year it is not something that can simply be prepared at the end of the financial year. An issue arising on the first day of the year is as important for SAO purposes as something that happens at the balance sheet date.

The SAO is unlikely to have hands-on responsibility for the day-to-day processes undertaken in ensuring the entity meets its filing obligations. Instead it is the SAO’s responsibility to ensure that they have the appropriate control framework in place for the identification and management of risks, suitable controls and monitoring activities as well robust lines of information and communication in place to mitigate risk as far as is practicable to do so.

They may delegate such responsibility as they see fit, but they must ensure that if they do, the person to whom they delegate has sufficient capabilities and experience to meet the necessary requirements. In addition, the company may outsource some of its functions to third party providers (eg payroll). The SAO

More on Senior accounting officer: