Which companies must have a senior accounting officer?

By Tolley

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

  • Which companies must have a senior accounting officer?
  • Qualifying company
  • Groups
  • Companies leaving or joining a group
  • Exclusions

Qualifying company

The Senior Accounting Officer (SAO) measure only applies to qualifying companies. To qualify a company must be incorporated in the UK as described in Companies Act 2006, s 1(1) .

FA 2009, Sch 47, paras 15, 18; SAOG11100, SAOG11210; De Voil Indirect Tax Service V5.214 (subscription sensitive)

In addition a company is a qualifying company if, for the preceding financial year, it has either:

  • alone or when aggregated with the turnover of other UK companies in the same group on the last day of the company's previous financial year, its turnover is more than £200 million
  • a relevant balance sheet total, either of its own or when its balance sheet total is aggregated with those of other UK companies in the same group, of more than £2 billion

Typically this will be companies with an HMRC Customer Relationship Manager (CRM).

Please note that it is possible for a company to be qualifying company even if:

  • at the beginning of a financial year it is in administration or liquidation
  • during the course of a financial year it enters administration or liquidation

A joint venture may be within the scope of the SAO provisions and the responsible officers will be required to determine whether the joint venture meets the conditions.


The following definitions apply in relation to test for qualifying companies.


This is, as defined in Companies Act 2006, s 474 , and this states that turnover means the amount derived from the provisions of goods or services within the company's ordinary activities after deduction of trade discounts, VAT and other

More on Senior Accounting Officer: