Introduction to SAO requirements

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:

  • Introduction to SAO requirements
  • Introduction
  • Taxes covered by SAO regime
  • Who is the SAO?
  • Change of SAO
  • Notification
  • Qualifying company
  • Time limits
  • The role of the SAO
  • Penalties


The senior accounting officer (SAO) regime was introduced by FA 2009, Sch 46 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 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 who is the SAO, the companies within the regulations, the taxes covered and notification of the SAO. This note should be read in conjunction with the Duties of an SAO and Penalties for breaches of SAO rules guidance notes.

The key legislation is found at FA 2009, Sch 46.

Taxes covered by SAO regime

The regime covers many of the main taxes:

  • Corporation Tax (CT)
  • Value Added Tax (VAT)
  • Pay As You Earn (PAYE)
  • Stamp Duty Land Tax (SDLT) and Stamp Duty Reserve Tax (SDRT)
  • Insurance Premium Tax (IPT)
  • Petroleum Revenue Tax (PRT)
  • Customs duties
  • Excise duties (including Air Passenger Duty)
  • Bank levy

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:

  • National Insurance contributions (NICs) and other employer responsibilities such as National Minimum Wage and Student Loans
  • ‘operational taxes’, for example chargeable events reporting
  • environmental taxes
  • Construction Industry Scheme

In practice, the fact that certain taxes are excluded is

More on Senior accounting officer: