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HMRC internal manual

Senior Accounting Officer Guidance

In what circumstances is a penalty chargeable: Senior Accounting Officer identity not notified by company

Customer Compliance Managers (CCMs), the Mid-sized Business Customer Engagement Team (CET) or a Caseworker may become aware that

  • the Senior Accounting Officer’s (SAO’s) main duty has not been carried out
  • an SAO certificate has not been provided, or
  • a SAO certificate has been provided containing a careless or deliberate inaccuracy,

but the company has not yet notified HMRC of its SAO for the period covering the failure. This may be because the company has failed to provide a notification for the period or because the notification is not yet due.

In such cases the CCM, CET or Caseworker should take steps to ascertain from the company who its SAO(s) was/were so that the failure(s) can be discussed with the SAO(s)

If the company does not provide this information the CCM, CET or Caseworker may have evidence or reasonable grounds to infer who, in the company’s reasonable opinion was the director or officer who had overall responsibility for the company’s financial accounting arrangements for the period(s) in question and was therefore the SAO. See SAOG12200.

For example the CCM, CET or Caseworker may gather evidence of who the company’s SAO or SAOs were likely to be from their experience of dealing with the company. If this is the case and there has been a failure the CCM, CET or Caseworker should follow the penalty procedures set out in SAOG19000+.

Paragraph 16 Schedule 46 FA 2009