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HMRC internal manual

Senior Accounting Officer Guidance

Senior Accounting Officer main duty: reasonable steps: making tax sensitive judgements

Applying judgement around tax sensitive decisions is part of the ‘appropriate tax accounting arrangements’.

Companies are expected to take reasonable steps to ensure that those making the decisions

  • base them on reasonable interpretation of accurate information
  • in full knowledge of tax law, and
  • having taken appropriate advice.

If this is the case, the fact that this judgement may differ from that made by HMRC does not mean that the tax accounting arrangements are inappropriate. See SAOG14490 for examples of this situation.