Senior Accounting Officer must provide a certificate to HMRC: what happens if a qualifying company is struck off
A Senior Accounting Officer (SAO) is still obliged to provide a certificate or certificates in accordance with the guidance below.
The person who is the SAO at the time a company ceases to exist can never be replaced in that role. That person will remain responsible for any certificates that they are obliged to provide in accordance with SAOG15800.
A qualifying company which is not a Plc has a 31 December financial year end. An SAO certificate must normally be provided within 9 months of the period end.
The company is struck off on 27 May 2015 and at that point no SAO certificate has been provided for the financial year ended 31 December 2014. This must be provided by the person who was the SAO on 27 May 2015.
However, there is at least one further financial year of this company for which an SAO certificate will be required. That or those financial years will be established by applying the rules in the Companies Act 2006, see SAOG10500. Those financial years will end for SAO purposes with the latest financial year that encompasses the date of striking off. See worked examples below.
Period 01/01/2014 to 31/12/2014
- Certificate required - Yes
- Deadline date - 30/09/2015
- Reason: SAO for a non-Plc has 9 months from end of AP to provide certificate to HMRC
Period 01/01/2015 to 31/12/2015
- Certificate required - Yes
- Deadline date - See different scenarios 1 to 3 below
- Reason: Deadline date varies depending on whether the company makes a change of accounting reference period notification to Companies House
If the company does not notify Companies House that there is a change of accounting reference period, that further financial year will be the year ended 31 December 2015
- Certificate must be provided by 30 September 2016 (30 June 2016 for a Plc).
If the company notifies Companies House stipulating an accounting reference date, then providing that the end date is later than the striking off, that striking off date (27 May 2015) will become the financial year end. That period will be the final financial year for SAO purposes
- Certificate must be provided by 27 February 2016 (27 November 2015 for a Plc).
If a new accounting reference date that precedes the striking off is notified to Companies House, say on 31 March 2015, the company will have:
- one financial year from 1 January 2015 to 31 March 2015, and then
- in the absence of any other notification, another financial year ended 12 months later - 31 March 2016.
An SAO certificate will be required for both of these financial years as they cover periods up to the date when the company was struck off
Certificates must be provided no later than:
- by 31 December 2015 (30 September 2015 for a Plc), and
- by 31 December 2016 (30 September for a Plc) respectively.
The time limits for submitting these certificates will remain either 6 months (for a Plc) or 9 months after the end of the financial year, see SAOG15700.
However, in the knowledge that there can be no more tax accounting after the striking off date and to enable SAO’s to complete a certificate whilst matters are fresh in their minds, we will accept a certificate completed after the striking off date rather than after the end of the financial year.