Senior Accounting Officer Main Duty: request to HMRC for view on approach to main duty
The Senior Accounting Officer (SAO) provisions make the SAO accountable for a company having tax accounting arrangements that allow it to calculate its tax liabilities accurately.
As part of their normal relationship management Customer Compliance Managers (CCMs) will be in ongoing discussion with their businesses about risks in their tax accounting arrangements and what the business may do to reduce these risks. (Note that for a Mid-sized Business customer such a discussion with a Caseworker is less likely to take place.)
While the SAO may reasonably make assumptions from these discussions about the extent to which HMRC is likely to agree that they are fulfilling the main duty the opinions expressed during these discussions do not constitute an agreement that the tax accounting arrangements are appropriate.
In some cases an SAO may ask HMRC to specifically give a view on whether they are fulfilling the main duty in their proposed approach. The responsibility for ensuring the company has appropriate tax accounting arrangements rests with the SAO.
In these situations a CCM, the Mid-sized Business Customer Engagement Team (CET) or a Caseworker must make it clear that any statements they make should not be taken to mean that they agree that the company has established and maintained appropriate tax accounting arrangements or that the SAO can submit an unqualified certificate. CCMs, the CET or a Caseworker must however draw to the SAO’s attention any matter that they have identified that will, or may, prevent the SAO meeting the main duty, see SAOG14000.