Duties of a senior accounting officer

By Tolley
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The following Value Added Tax guidance note by Tolley provides comprehensive and up to date tax information covering:

  • Duties of a senior accounting officer
  • Who will be the SAO?
  • Change of SAO
  • Reasonable steps
  • Certificate
  • VAT groups
  • Standing data
  • Mergers and acquisitions

It is the personal responsibility of the senior accounting officer (SAO) to make sure the company takes reasonable steps to establish, maintain and monitor the adequacy of their accounting systems for the production of accurate tax returns. They must also provide a certificate to HMRC at the end of the financial year. The SAO must maintain and monitor the appropriate tax accounting arrangements and identify any areas which do not meet the requirements. They should do this on an ongoing basis, and it should not ideally be left until the end of the financial year.

SAOG14420; SAOG14430; De Voil Indirect Tax Service V5.215 (subscription sensitive); FA 2009, Sch 46, para 16

The SAO is unlikely to have hands on responsibility for the day to day processes undertaken in ensuring the entity meets its filing obligations. They may delegate such responsibility as they see fit, but they must ensure that if they do, the person they delegate to 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 should ensure that the third party has the capabilities and experience that is required.

Who will be the SAO?

The SAO for most groups and companies is the director or officer of the company, or group, who has overall responsibility for the company’s financial arrangements. In certain circumstances there could be more than one SAO in a group of companies, for example if there are a number of subsidiaries who have different processes and accounting arrangements such that no one individual could be said to have the required level of oversight. In these circumstances a certificate is required from each SAO.

Companies Act 2006, ss 250 , 1173 ; SAOG12100; SAOG12200

Where an SAO is responsible for a number of group companies, they will have to

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