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HM Revenue and Customs Brief 15/14 - Senior Accounting Officer updates

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Issued: 9 April 2014

Senior Accounting Officer guidance updates

1. Introduction

This Revenue & Customs Brief draws attention to recent updates to HMRC'S SAO Guidance (SAOG) to clarify our policies and reflect administrative changes to our operational procedures. These include:

  • clarification of our view regarding the treatment of dormant companies for the purpose of the Senior Accounting Officer (SAO) rules (SAOG11210; SAOG11220)
  • clarification of our view about the application of the SAO rules where a qualifying company has not notified HMRC of the name of its SAO (SAOG12200; SAOG16500; SAOG18400; SAOG18500; SAOG18550; SAOG18600; SAOG21200)
  • clarification of our view that the main duty of an SAO is to establish and maintain appropriate tax accounting arrangements which may affect returns made in the current year, for previous years or for future years as well as any other 'in year' filings (SAOG14340)
  • clarification that where the SAO has failed in their main duty, the onus is on the SAO to fulfil their obligations rather than on the Customer Relationship Manager (CRM) to prompt the SAO into action (SAOG18400).
  • guidance on the revised process CRMs must follow where they believe there has been a SAO failure, including a revised penalties authorisation process (SAOG19000+).
  • guidance for CRMs on accounting procedures to use for penalties where no Unique Tax Reference (UTR) exists (SAOG21500; SAOG21510; SAOG21600).
  • updated guidance on the appeals process (SAOG22400+)
  • various updates throughout the guidance to reflect the changes to how HMRC is organising its compliance work.

We have also updated the guidance to reflect a minor alteration to our policy regarding the provision of a company's SAO notification and the SAO's certificate (SAOG13300; SAOG15600).

These updates and amendments will apply from the date of publication.

2. Who needs to read this?

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

3. 'Administrative' updates


HMRCs Penalties Consistency Panel maintains an overview of any cases involving SAO related penalties to ensure consistent application of the legislation. We are maintaining this process, but streamlining it to make it more efficient.

We are also clarifying the guidance for CRMs about the operational process for making assessments and how to handle appeals, and providing instructions about other administrative matters such as how to account for a penalty where the taxpayer does not have a UTR (Unique Taxpayer Reference).

4. Clarification of existing policies

We have updated the guidance to clarify our views in relation to some queries we have received since the last SAOG amendments. These updates do not reflect new policies, but we are keen to communicate these clarifications more widely.

SAOG11210 and SAOG11220 have been amended to more clearly reflect our view that dormant companies may be qualifying companies for the purpose of the SAO rules.

We have update SAOG14340 to clarify our view that the main duty of an SAO is to establish and maintain appropriate tax accounting arrangements which may affect returns made in the current year, for previous years or for future years as well as any other 'in year' filings for the taxes within scope of the SAO legislation.

SAOG18400 has been amended to reflect our view that where the SAO has failed in their main duty, the onus is on the SAO to fulfil their obligations rather than on the CRM to prompt the SAO into action.

A number of pages have been amended to reflect how the SAO rules are applied where the company has not yet notified HMRC of the name of its SAO.

5. Revised policy

Previously we accepted company SAO notifications and SAO certificates on the same piece of paper. However this led to confusion for both our CRMs and customers. To reduce this confusion we will now only accept these two items separately. The guidance at SAOG13300 and SAOG15600 has been amended to reflect this.

6. Applying the updated guidance

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


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Crown Copyright 2014.

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Article Published/Sorted/Amended on Scopulus 2014-04-22 12:19:57 in Tax Articles

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