Senior accounting officer – introduction

By Tolley

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

  • Senior accounting officer – introduction
  • Taxes covered
  • Tax accounting arrangements
  • Definitions
  • Meaning of tax accounting arrangements
  • Monitor and maintain
  • Qualifying company
  • Notifying HMRC

The senior accounting officer (SAO) regime was introduced by FA 2009 with the aim of ensuring that qualifying companies have adequate systems in place so that the correct tax liabilities are reported to HMRC. The SAO regime covers a range of taxes and duties.

The SAO regime is clearly linked to HMRC’s Business Risk Review process for large businesses. Groups that are able to sign a 'clean' SAO certificate, and are able to demonstrate to their HMRC customer relationship manager (CRM) the basis upon which that conclusion was reached, are more likely to be regarded by HMRC as representing a reduced risk when it considers the group’s governance and ability to pay the right tax at the right time.

This note should be read in conjunction with the following guidance notes:

  • Duties of senior accounting officer
  • Which companies must have a senior accounting officer
  • Senior accounting officer – penalties and assessment
Taxes covered

The SAO provisions apply to the tax accounting arrangements in operation to ensure the correct liabilities are returned to HMRC for:

  • Corporation Tax (CT)
  • Value Added Tax (VAT)
  • Pay As You Earn tax (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

FA 2009, Sch 46, paras 16, 14(3); SAOG10300

The following duties and taxes are excluded from the regime:

  • National Insurance contributions (NICs) and other employer

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