Tax compliance risk management process for customers managed by Large Business: re-considering a certificate once an error has been found
If the Customer Relationship Manager (CRM) finds an inaccuracy in the tax liability returned by a company, this in itself will not necessarily mean that the Senior Accounting Officer (SAO) certificate was inaccurate.
The CRM should investigate the reasons behind the inaccuracy through discussion with the company. It is possible that an inaccuracy will have arisen despite the company having appropriate tax accounting arrangements. In such a situation there is no need to look again at the SAO provisions, although of course other provisions may apply (Schedule 24 FA07 for example, see CH80000). However, the CRM must re-consider the certificate if they believe that the inaccuracy was connected with tax accounting arrangements that were not appropriate.
If, given the knowledge of the inaccuracy and the understanding as to how and why it arose, the CRM is satisfied that
- the certificate that the SAO provided for the financial year is inaccurate and
- in providing the certificate, the behaviour of the SAO was careless or deliberate
the CRM must follow the guidance at SAOG19000.