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HMRC internal manual

Senior Accounting Officer Guidance

From
HM Revenue & Customs
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What is a qualifying company: determination must be made for each financial year

The Senior Accounting Officer (SAO) provisions only apply to a qualifying company. The responsible officers of a company must determine whether it is a qualifying company. For a company to be a qualifying company for a financial year it must meet the conditions set out in SAOG11210.

It is possible for a company to be a qualifying company in one financial year, not a qualifying company the year after, then a qualifying company again the year after that and so on. The fact that it was a qualifying company in say the year ended 30th June 2016 is not relevant to the determination for the financial year ended 30th June 2017.

For example, in the case of a non-grouped company X Ltd that is UK incorporated and with a balance sheet total below £2 billion in each of the following financial years the turnover and the company’s qualifying status is as follows:

Financial year ended Turnover Is the company a qualifying company for the year?
     
31 December 2009 £220 million No. The SAO provisions do not apply to this financial year because it did not begin on or after 21 July 2009. You do not therefore need to know the company’s turnover in the financial year ended 31 December 2008.
31 December 2010 £180 million Yes. X Ltd is a qualifying company for the financial year ended 31 December 2010 because it satisfies the turnover condition: the turnover in its preceding financial year (£220 million) was more than £200 million. So the SAO provisions apply to X Ltd for the 2010 financial year.
31 December 2011 £250 million No. X Ltd is not a qualifying company for the financial year ended 31 December 2011 because it does not satisfy the turnover condition: the turnover in its preceding financial year (£180 million) was not more than £200 million. So the SAO provisions do not apply to X Ltd for the 2011 financial year.
31 December 2012 £300 million Yes. X Ltd is a qualifying company for the financial year ended 31 December 2012 because it satisfies the turnover condition: the turnover in its preceding financial year (£250 million) was more than £200 million. So the SAO provisions apply to X Ltd for the 2012 financial year.