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HMRC internal manual

Senior Accounting Officer Guidance

Senior Accounting Officer main duty: reasonable steps: VAT representative 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.

The Senior Accounting Officer (SAO) of the representative member company must ensure that they receive accurate information from the other group companies as part of their reasonable steps to establish and maintain that company’s appropriate tax accounting arrangements, see SAOG14335.

Those reasonable steps in relation to VAT may include

  • making sure that there are appropriate accounting arrangements within the other group companies,
  • monitoring those arrangements,
  • capturing and recording relevant information, and
  • making sure that the necessary information from those companies is received and actioned by the representative member company.

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.