HMRC internal manual

Senior Accounting Officer Guidance

SAOG14512 - Senior Accounting Officer main duty: reasonable steps: Example 3 - Customs data on import and export declarations

The examples in SAOG14510 - 14515 illustrate some situations where reasonable steps are taken. The examples illustrate the point but are not exhaustive.

Example 3 - Customs data on import and export declarations

An import/ export company has to make Customs declarations. There are many data fields on an Import or Export Declaration. Each of the data items must be created, validated and maintained. A number of the data items are Customs specific and others have wider significance. These declarations can be generated by a third party contracted by the business or by different people throughout the business.

Exercising reasonable control can involve a wide range of people outside the tax or accounting function. An error in an entry in a data field leads to a substantial under-declaration of Customs duties. The Customer Compliance Manager (CCM) or Mid-sized Business Caseworker finds that steps taken by the Senior Accounting Officer (SAO) involve:

  • obtaining assurance about the validation process for all data items to confirm that they are declared correctly, completely and in accordance with the law, as well as of the maintenance processes for the data via regular review of standing data
  • clearly documented and tested security and access levels allowing staff or third party personnel to generate or change data
  • ensuring that staff are appropriately trained for their role or that third parties are appropriately qualified and experienced to undertake any activities
  • obtaining assurance about the process for classifying goods for Customs purposes and maintaining correct classification of products according to current Tariff information
  • documented procedures for the classification of goods for import and export purposes, Valuation of Goods for Customs Purposes, and so on.

Although there has been an error, and the under-declaration has to be corrected, the error is an isolated example of human error. The CCM or Caseworker forms the opinion that the SAO has taken reasonable steps to ensure that the accounting arrangements of the company around these declarations are appropriate.