Introduction to SAO requirements

Produced by Tolley in association with

Corporation Tax

Guidance

SAO regime ― background

The senior accounting officer (SAO) regime ensures that qualifying companies have adequate tax accounting arrangements in place so that the correct tax liabilities are notified to HMRC.

The SAO regime requires a qualifying company to appoint an SAO. It is the personal responsibility of the SAO, and in fact their main duty, to make sure that the company takes reasonable steps to establish, maintain and monitor the adequacy of its tax accounting arrangements, to ensure the production of accurate tax returns and provide a certificate to HMRC after the end of the financial year. The SAO must also identify any areas that do not meet the requirements and disclose these failures to HMRC as part of a certification process.

The regime was brought in to reinforce the risk assessment approach that HMRC uses for large businesses. It brings personal accountability to senior finance personnel for the failures of a company to furnish timely and accurate tax returns.

This guidance

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Philip Rutherford

Senior Tax Director at Molson Coors Brewing Company

Phil is the Senior Tax Director for Molson Coors' European operations. He has responsibility for both direct and indirect taxes across both EU and non-EU states. Prior to this, Phil was responsible for Molson Coors UK tax affairs covering all major taxes and duties. Phil trained at KPMG LLP, where he worked for 8 years, specialising in tax investigations across both direct and indirect tax.

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