HM Revenue and Customs Brief 12/16 - Senior Accounting Officer guidance
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Updated 1 June 2016
Purpose of this brief
This revenue and customs brief draws attention to recent
updates to HM Revenue and Customs (HMRC) Senior
Accounting Officer guidance (SAOG)
to clarify our practice and reflect administrative changes to our
operational procedures. These include:
- a change of practice allowing submission of certificates by
electronic means in addition to the currently accepted methods (SAOG
15600 and 15700)
- extensive updates to reflect organisational change within HMRC and the
role of Wealthy and Mid Size Business Compliance (WMBC)
- new examples of how groups and aggregation should be
11280 and 11301)
- clarification of our view on the inability to delegate the SAO role (SAOG
12100) and our view of time limits for short or long accounting periods
13410 and 15710)
- clarification about when requests for extensions to time
limits for SAO
notification or certificates will be considered (SAOG
13100 and 15700)
- clarification of the SAO role
where a company is struck off (SAOG13500 and 15900)
- various updates throughout the guidance to reflect the
changes to how HMRC
is organising its compliance work
These updates and amendments will apply from the date of
This brief should be read by companies and SAOs falling
within the SAO
rules and their agents. Further detail is given below.
has insisted SAOs
must provide an original signed paper certificate. HMRC will now
accept certificates through any recognised paper or electronic format
including letter, fax or email. Certificates must still include the
identifiable signature of the SAO.
Certificates provided before the publication of the guidance
changes will only be valid if they meet the previous requirements ie
are original signed paper certificates.
of existing practices
have updated the guidance to clarify our views in relation to some
queries we have received since the last SAOG
amendments. These updates donít reflect new practices, but we are keen
to communicate these clarifications more widely.
SAOG11301 has been amended to include situations where a newly
incorporated company (or a company whose turnover and/or balance sheets
are below qualification level) joins a group.
SAOG11400 has been amended to add Industrial and Provident
societies and Cooperative and Community Benefit Societies to the list
of non-qualifying bodies.
SAOG12100 has been updated to clarify our view that the SAO role
canít be delegated to an agent or advisor of the company.
New pages SAOG
13410 and 15710 have been added to clarify HMRCís view that
certificates for short and long accounting periods should match the
Companies House filing period.
New page SAOG13500 has been added to clarify HMRCís view that
is still responsible for outstanding certificates when a company is
SAOG13100 and 15700 have been amended to clarify that requests
for time extensions must still allow sufficient time for HMRC to receive,
consider and provide a response.
Previously all qualifying companies were within the Large
Business portfolio with an assigned Customer Relationship Manager (CRM). The
revised guidance (SAOG
17000) explains the differences in customer management due to some
customers being managed by WMBC
which doesnít have a dedicated CRM role.
have also clarified confidentiality procedures when gathering
information or discussing issues with a company around personal
penalties for SAOs.
Also we have provided additional information on the detail to be
included in penalty notices.
These updates to the SAOG
will apply from the date of publication.
Issued: 24 May 2016.
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Article Published/Sorted/Amended on Scopulus 2016-06-02 00:00:00 in Tax Articles