Senior Accounting Officer

An SAO is a key individual in a large group that is responsible for certifying that the group has appropriate tax accounting procedures to ensure that the tax liabilities are in place.

What is an SAO?

An SAO is a key individual in a large group that is responsible for certifying that the group has appropriate tax accounting procedures to ensure that the tax liabilities are in place. This person has a statutory duty to certify personally that the Group’s accounting systems and processes are suitable to allow the Group to perform their tax reporting responsibilities correctly. The SAO needs to:

  • Monitor the accounting arrangements of the company
  • Identify the areas in which there are any inappropriate tax accounting arrangements
  • Report to HMRC on an annual basis that this has been done.

Key qualifying criteria for the company

  • £200m UK group turnover; or
  • £2bn balance sheet

What does an SAO need to do?

  • The company needs to notify HMRC of the name of the SAO by a separate notification each financial year it is a qualifying company
  • It needs to prepare an annual certificate to HMRC which personally certifies that the Group is operating with appropriate tax accounting controls in place.

What are the penalties?

The SAO is personally liable for a penalty of £5,000 for:

  • Failure to notify HMRC of the name and contact details of the SAO
  • Failure to carry out the SAO duties correctly
  • Failure to provide a certificate to HMRC of compliance or providing one with a careless or deliberate inaccuracy

What do I need to do?

If your UK group meets the criteria above you will need to contact your usual F&L contact as soon as possible, or any of the F&L tax team.

Melissa Christopher
Partner
+44 (0)20 7430 5894 / mchristopher@fitzandlaw.com

Mark Dent
Manager
+44 (0)20 7430 5960 / mdent@fitzandlaw.com

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