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HMRC internal manual

Senior Accounting Officer Guidance

Senior Accounting Officer Main Duty: overview

To comply with the Senior Accounting Officer (SAO) provisions, an SAO must

  • carry out a main duty during the financial year and
  • provide a certificate to HMRC after the end of the financial year.

An SAO’s main duty is to take reasonable steps to ensure that the company establishes and maintains appropriate tax accounting arrangements. As part of this duty, an SAO must monitor the arrangements and identify any respects in which the arrangements fall short of the requirement.

Tax accounting arrangements are

  • the framework of responsibilities, policies, appropriate people and procedures in place for managing the tax compliance risk, and
  • the systems and processes which put this framework into practice.

The tax accounting arrangements must allow for the tax liabilities of the company to be calculated accurately in all material respects.

The steps an SAO must take to ensure the company establishes and maintains appropriate tax accounting arrangements might include such responsible actions as

  • establishing and monitoring processes
  • ensuring staff and businesses to whom work is out-sourced are appropriately trained and qualified to undertake their functions
  • instituting improvements where shortcomings have been found in the tax accounting arrangements.

The SAO must perform the main duty throughout the period of their responsibility. It is not something that they can merely give attention to at the end of a year.

An SAO may ask HMRC to give a view on whether they are fulfilling the main duty in their proposed approach. See SAOG14600 for guidance on dealing with such a request.

Although the person holding the role of SAO may change during a financial year, in considering the main duty it is necessary to look at the period within the financial year covered by each SAO. Each SAO has a responsibility to meet the main duty for the period of the financial year in which they are the SAO, see SAOG14700.