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Revised SAO guidance comes into effect

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HMRC has published revisions to its guidance on the senior accounting officer (SAO) regime, the details of which are set out in Revenue & Customs Brief 19/13. An SAO’s main duty is to take reasonable steps to ensure that the company establishes and maintains appropriate tax accounting arrangements. As part of this duty, an SAO must monitor the arrangements and identify any respects in which the arrangements fall short of the requirement.

The revised SAO guidance, which applies from 5 August 2013, concerns a number of updates to HMRC’s Senior Accounting Officer Guidance Manual, which the department regards as policy clarifications, rather than changes. These include: the responsibilities of companies whose shares are held by a parent on trading account (such as banks or private equity groups) to comply with their SAO obligations; use of correct SAO certificates; clarification of HMRC’s interpretation of the ‘turnover test’, clarification of HMRC’s view on the operation of the SAO rules when a qualifying company fails to identify its SAO, and some slightly revised wording to the guidance in paras SAOG14330, SAOG14352 and SAOG14353 to improve consistency of language with the SAO legislation, as well as some updates regarding HMRC’s view on the duties of an SAO for the representative company of a VAT group provide clarification regarding an issue not previously explicitly addressed by the SAO guidance.