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HMRC internal manual

Senior Accounting Officer Guidance

Senior Accounting Officer main duty: reasonable steps: example of standing data

SAOG14440 explains the general approach to standing data.

These examples are illustrative, not exhaustive. They are not intended to establish a standard to which all are expected to adhere.


Accounting systems often have tax codes (VAT rates) ascribed to certain cost ledger codes. Where a company already has appropriate arrangements in place to ensure that tax codes are correct we do not expect them to do anything further to comply with the Senior Accounting Officer (SAO) provisions. However, where companies have no means of ensuring that tax codes are correct or have reason to believe that they are incorrect, we do expect them to take reasonable steps to rectify this where standing data is used to calculate VAT liabilities for accounting periods covered by these provisions. This is unlikely to mean that a company/ group will have to go back through all its codes and standing data at commencement.


Similarly payroll records contain standing data such as tax codes and dates of birth which help to determine the relevant PAYE liabilities. Again, any errors identified would need to be appropriately dealt with, but companies should be able to rely on standing data in use at the date of commencement for the purposes of the SAO provisions.