Senior Accounting Officer main duty: reasonable steps: establishing and maintaining processes
Qualifying companies are large businesses. All have processes to support tax accounting. Some of these may have been in place for a long time.
A Senior Accounting Officer (SAO) must consider, as part of the reasonable steps they take, whether existing processes within the tax accounting arrangements are sufficiently robust such that any inaccuracy in a return or document containing figures arising from any of those processes would be unlikely to result in a liability to any penalties under tax law.
An SAO must also consider how the company should maintain the existing processes, and whether it may need to enhance those processes or replace them with an alternative.