HM Revenue and Customs Brief 15/14 - Senior Accounting Officer updates
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Issued: 9 April 2014
Senior Accounting Officer guidance updates
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
- 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;
- 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
- 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;
- 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
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
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Article Published/Sorted/Amended on Scopulus 2014-04-22 12:19:57 in Tax Articles