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HMRC internal manual

Senior Accounting Officer Guidance

Tax compliance risk management process for customers managed by Large Business: checking claim there is no SAO

Where, unusually, a Customer Compliance Manager (CCM) receives a claim that

  • there is no person within the company or group who had the responsibility for the financial accounting arrangements for a company, and
  • therefore no notification can be made,

they must test this claim.

We might receive such a claim in response to a question we ask as to why there has been no notification.

If as a result of the CCM’s enquiries HMRC is satisfied that no such person could be identified there will in fact be no Senior Accounting Officer (SAO). In such a case there can be no penalty on the company for failure to make a notification and no penalties for a failure to perform the main duty or provide a certificate.

The CCM should, however, take such a claim into account as potentially a significant risk factor when risk-assessing the company’s accounts.

This type of claim may occur in administration or liquidation cases where, unusually, the administrator or liquidator

  • does not meet the definition of the SAO, see SAOG12200, and
  • cannot identify a person who does.