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HMRC internal manual

Senior Accounting Officer Guidance

Tax compliance risk management process for customers managed by Large Business: response to the provision of a certificate - the CCM expects a certificate and one is provided

This expectation will arise where the company has already notified details of its Senior Accounting Officer (SAO) or, where it has not done so, where the Customer Compliance Manager (CCM) has established these details from previous discussions with the company.

The CCM must check that the person who has provided the certificate was notified to HMRC as an SAO by the company, see SAOG16300, or became the SAO after the end of the financial year, see SAOG12500. If the person was not an SAO, the CCM must consider whether there is a notification failure on behalf of the company and / or a failure by a person who was an SAO of the company to provide a timely certificate.

  • If an SAO provides a timely certificate, there is no penalty to consider for failure to provide a certificate. The CCM should refer to SAOG16700 for guidance on considering the nature and content of the certificate.
  • If an SAO provides a certificate but does not do so within the time allowed, once the apparent failure to provide a timely certificate comes to the attention of a HMRC officer, the CCM must

    • consider whether a penalty may be chargeable on that SAO, see SAOG18500, or a successor SAO who has not provided a certificate at all, see SAOG18700, and
    • if so, follow the step by step guidance at SAOG19000 to take the appropriate penalty action.

Whether the certificate provided is timely or not, the CCM must file the certificate and reconsider any issues above and/or its content as part of the risk assessment of the company/ group.