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HMRC internal manual

Senior Accounting Officer Guidance

Tax compliance risk management process for customers managed by Large Business: overview

The Business Risk Review is the process by which a Customer Compliance Manager (CCM) determines where a group sits on the compliance spectrum.

Where possible, HMRC relies on large companies’ own governance, systems and processes to manage risks to tax compliance. As part of the Business Risk Review a CCM evaluates how the group’s approach to these factors mitigates the inherent risks to tax compliance within the group.

The Senior Accounting Officer (SAO) provisions fully fit with this approach. The provisions make the SAO of a qualifying company responsible for ensuring that the company establishes and maintains appropriate tax accounting arrangements that allow the tax liabilities of the company to be calculated accurately in all material respects.

So the CCM must consider whether and how the group and the SAO have complied with the SAO provisions as part of the Business Risk Review. To do this the CCM should

  • review whether any companies within the group meet the conditions to be a qualifying company and are therefore subject to the SAO provisions, see SAOG11000
  • if the group contains a qualifying company or companies, check whether

    • the group or company has given a timely notification of the SAO details to HMRC, see SAOG16300
    • the SAO has given a timely certificate to HMRC, see SAOG16500 and SAOG16600
  • consider the nature and content of the certificate, see SAOG16700
  • discuss any risks raised in the SAO certificate with the company, see SAOG16800
  • consider in the light of these and wider risk assessment issues whether the SAO has complied with the main duty, see SAOG16900, and/or has submitted an inaccurate certificate, see SAOG16720.

A CCM will usually already have been allocated to a customer who will meet the conditions to be a qualifying company, see SAOG11000.