Reflecting on the Senior Accounting Officer regime
Tony Monger of Mazars looks back on the Senior Accounting Officer regime and examines how it is operating 10 years on. He covers the basics, the duties of the SAO, appropriate tax accounting arrangements, penalties and more.
The Senior Accounting Officer (SAO) regime has been with us a full 10 years, which seems astonishing when you consider how many companies (especially those who are newly entering the regime) seem to be unaware of its existence and find that they have fallen foul of its requirements. It is worth noting that the same criteria apply for the requirement for a company to publish its tax strategy, but that is something to worry about on another day.
HMRC has faced reducing resources to fulfil its many duties for some time. Its solution has been to allocate resources according to tax risk; the higher the risk, the greater the resources. The SAO system and the SAO’s certificates effectively work to categorise big companies into low and high-risk groups. An ‘unqualified’ certificate indicates a lower risk, but a ‘qualified’ certificate, with identification of problems, will increase the risk – and inform HMRC as to where best to apply its resources.