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HMRC internal manual

Senior Accounting Officer Guidance

What is a qualifying company: conditions for a qualifying company: CCM action with turnover

A Customer Compliance Manager (CCM) should be prepared to discuss with a company whether any particular income stream of that company should be counted as turnover for the purposes of determining whether it is a qualifying company.

If a company is holding itself out as a qualifying company there is normally no need for the CCM to make any enquiries as to the turnover figure.

However a company which the CCM would expect to be a qualifying company on the basis of its turnover may contend that that it does not meet the turnover ‘test’. In that case the CCM must explore with the company how the turnover figure has been calculated and, with accountancy advice where necessary, establish whether the company has provided the correct figure or whether this should be in some other amount exceeding £200 million.

If the CCM concludes that the company’s turnover for the preceding financial year was sufficient to make it a qualifying company they will have to consider:

  • the company’s failure to notify HMRC of its Senior Accounting Officer (SAO) or SAOs, see SAOG13000 
  • the failure of the SAO to provide a timely certificate, see SAOG15000 
  • the failure of the SAO to meet the main duty, see SAOG14000.

If penalties arise from any of these failures the appeal rights of the company and the SAO against the penalty assessments will form the basis of the company’s challenge to HMRC’s view of the amount of turnover.

FA09/SCH46/PARA15 (2) & (3)