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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 applied (SAOG 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 (SAOG 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 publication.

Readership

This brief should be read by companies and SAOs falling within the SAO rules and their agents. Further detail is given below.

Background

Previously HMRC 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.

Clarification of existing practices

HMRC 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 a SAO is still responsible for outstanding certificates when a company is struck off.

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.

Administrative updates

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.

HMRC 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.

Applying the updated guidance

These updates to the SAOG will apply from the date of publication.

Issued: 24 May 2016.


About the Author

© Crown Copyright 2016.

A licence is needed to reproduce this article and has been republished for educational / informational purposes only. Article reproduced by permission of HM Revenue & Customs.



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Article Published/Sorted/Amended on Scopulus 2016-06-02 00:00:00 in Tax Articles

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