Introduction to SAO requirements

Produced by Tolley in association with Philip Rutherford
Introduction to SAO requirements

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

  • Introduction to SAO requirements
  • SAO regime ― background
  • Taxes covered by SAO regime
  • Who is the SAO?
  • Change of SAO
  • How to make a notification under the SAO regime?
  • What is a qualifying company under the SAO regime?
  • Time limits for SAO notification and certificate
  • The role of the SAO
  • Penalties for SAO failure

SAO regime ― background

The senior accounting officer (SAO) regime ensures that qualifying companies have adequate tax accounting arrangements in place so that the correct tax liabilities are notified to HMRC.

Very broadly, the SAO regime requires a qualifying company to appoint an SAO. It is the personal responsibility of the SAO, and in fact their main duty, to make sure that the company takes reasonable steps to establish, maintain and monitor the adequacy of its tax accounting arrangements to ensure the production of accurate tax returns and provide a certificate to HMRC after the end of the financial year. The SAO must also identify any areas that do not meet the requirements and disclose these failures to HMRC as part of a certification process.

The regime was brought in to reinforce the risk assessment approach to large businesses that HMRC uses. It brings personal accountability to senior finance personnel for the failures of a company to furnish timely and accurate tax returns.

This guidance note covers the background to the legislation, specifically what taxes are covered by the SAO regime, who can be an SAO, how to make a notification, what constitutes a qualifying company for SAO purposes and so on. This note should be read in conjunction with the Duties of an SAO and Penalties for breaches of SAO rules guidance notes.

For further information on the regime, see Simon’s Taxes D1.1306.

Taxes covered by SAO regime

The regime covers many of the main taxes:

  1. Corporation Tax (CT)

  2. Value Added Tax (VAT)

  3. Pay As You Earn (PAYE)

  4. Stamp Duty Land Tax (SDLT) and Stamp Duty Reserve Tax (SDRT)

  5. Insurance Premium Tax (IPT)

  6. Petroleum Revenue Tax (PRT)

  7. Customs duties

  8. Excise duties (including Air Passenger Duty)

  9. Bank levy

FA 2009, Sch 46, para 14(3); SAOG10300

If a tax is not included within the list of covered taxes it is excluded from the SAO regulations. The following notable duties and taxes are excluded:

  1. National Insurance contributions (NIC) and other employer responsibilities such as

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