HMRC is increasingly charging penalties to companies and senior accounting officers in respect of failures under SAO legislation. SAOs should be able to demonstrate a credible approach to the SAO requirements with contemporaneous supporting documentation. A number of common mistakes and pitfalls lead to these penalties. While the penalties are not particularly financially punitive, businesses should consider the impact on their reputation and their relationship with HMRC. SAOs who have identified a failure should bring this to the attention of their CRM and put the failure right without delay
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