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HMRC internal manual

Senior Accounting Officer Guidance

Tax compliance risk management process for customers managed by Mid-sized Business: overview

Where possible, HMRC relies on large companies’ own governance, systems and processes to manage risks to tax compliance. 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.

Whenever the Mid-sized Business Customer Engagement Team (CET) or Caseworkers engages with a large company or group they must consider whether and how the group and the SAO have complied with the SAO provisions. To do this the CET or Caseworker 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 SAOG17300
    • the SAO has given a timely certificate to HMRC, see SAOG17500 and SAOG17600
  • consider the nature and content of the certificate, see SAOG17700
  • discuss any risks raised in the SAO certificate with the company, see SAOG17800
  • consider in the light of these and wider risk assessment issues whether the SAO has complied with the main duty, see SAOG17900, and/or has submitted an inaccurate certificate, see SAOG17720.

Mid-sized businesses will not have a Customer Compliance Manager (CCM) allocated but may meet the conditions to be a qualifying company, see SAOG11000. If the CET or Caseworker receives a notification or an SAO certificate they should follow the guidance in SAOG17200 to SAOG17900.