Review of HMRC’s SAO guidance manual

HMRC’s Senior Accounting Officer guidance is good news for both SAOs and their companies as it provides greater clarity on some of the more challenging aspects of the rules, including the circumstances in which penalties may or may not be levied. However, key areas of subjectivity remain (not least the question of materiality) and so discussing matters as they arise with HMRC will continue to be of vital importance. In addition, monitoring industry practice will be crucial in moving toward the greater certainty sought by SAOs and those who provide assurance to them.