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HMRC internal manual

Senior Accounting Officer Guidance

Who is a Senior Accounting Officer: where a company is in administration or liquidation

It is possible for a company to be a qualifying company even if

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

The Senior Accounting Officer (SAO) provisions apply in this situation, despite the administration or liquidation.

As with any other situation, a qualifying company in administration or liquidation must identify its SAO. The person who meets the definition of the SAO could be the administrator or liquidator.

Unusually it may be claimed that there was no person within the company or group who had the responsibility for the financial accounting arrangements. If such a claim is made to HMRC, see SAOG16400.