The following Corporation Tax guidance note by Tolley in partnership with Philip Rutherford provides comprehensive and up to date tax information covering:
There are a number of penalties chargeable for failures in relation to the SAO regulations. In addition SAO failures should be considered in the context of the wider penalty framework as well as in terms of the impact that SAO failures may have on a company’s risk rating with HMRC.
For example, if a company has failed to establish and maintain appropriate tax accounting arrangements it will be difficult to demonstrate that it took reasonable care in relation to an error. See the Reasonable care ― inaccuracies in returns guidance note.
Similarly if a company does not have appropriate tax accounting arrangements in place it is likely to impact on the company’s risk rating. See the Business risk review guidance note.
The SAO provisions introduce three potential penalty positions, with one chargeable on the company and the other two assessable on the SAO personally. The three potential penalties are assessable as follows:
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