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HMRC internal manual

Senior Accounting Officer Guidance

Senior Accounting Officer main duty: appropriate tax accounting arrangements: VAT representative member company

Some groups of companies may appoint one of their number as a representative member to deal with all aspects of the group’s Value Added Tax (VAT) obligations and liabilities.

That representative member must have accounting arrangements in place that will enable it to calculate its VAT liability under the group arrangement accurately in all material respects. So the representative member needs to receive accurate information from the other group companies.

The Senior Accounting Officer (SAO) of the representative member company must ensure that this is the case as part of their reasonable steps to establish and maintain that company’s appropriate tax accounting arrangements, see SAOG14465.

The SAO of the representative company will also be responsible for providing a certificate see SAOG15000+. They will have to assure themselves as to whether or not they have received accurate information from the other group companies in order to complete this certificate accurately in relation to VAT.