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SAO guidance updated to allow electronic submission

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14th Jun 2016
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HMRC has issued an update to their senior accounting officer guidance (SAOG) to clarify their practice and reflect changes to its operational procedures, with perhaps the biggest change being the allowing of electronic submission of certificates.

The SAOG came into force in July 2009, and affects UK companies with a turnover of more than £200m or a relevant balance sheet total of more than £2bn for the preceding financial year, and has been updated a number of times since then, addressing a number of areas of uncertainty.

A company’s SAO is generally the executive with overall responsibility for the company’s financial accounting arrangements, and is responsible for ensuring that the company establishes and maintains appropriate tax accounting arrangements

Fixed penalties of £5,000 are charged to either the company or the SAO personally if they fail to meet their obligations, for example submitting the relevant documentation in an accurate and timely fashion.

Electronic submission

One of the major changes announced in the latest guidance was to allow submission of certificates by electronic means. Previously HMRC had insisted SAOs provide an original signed paper certificate, but the Revenue will now accept certificates through any recognised paper or electronic format including letter, fax or email.

Certificates must still include the identifiable signature of the SAO, and those certificates provided before the publication of the changes will only be valid if they meet the previous requirements – i.e. are original signed paper certificates.

Mark Kennedy, partner at Deloitte’s tax management consulting group called the submission reforms a “welcome concession”.

“Practically speaking this is going to make a big difference,” continued Kennedy, “particularly where there are difficulties with SAOs who have big roles and are constantly travelling, so it makes it easier to ensure compliance.”

Further clarification

The guidance also provided clarification that wk-here a company is struck off, in HMRC’s view an SAO is still responsible for providing its outstanding certificate.

SAOG12100 has been updated to clarify HMRC’s view that the SAO role can’t be delegated to an agent or advisor of the company.

The guidance provided new examples of how groups and aggregation should be applied (SAOG 11280 and 11301). SAOG11301 has been amended to include situations where a newly incorporated company (or a company whose turnover and/or balance sheets are below qualification level) joins a group.

New pages SAOG 13410 and 15710 have been added to clarify HMRC’s view that certificates for short and long accounting periods should match the Companies House filing period.

There have also been extensive updates to reflect organisational change within HMRC and the role of wealthy and mid-size business compliance (WMBC)

Previously all qualifying companies were within HMRC’s large business portfolio with an assigned Customer Relationship Manager (CRM). The revised guidance (SAOG 17000) explains the differences in customer management due to some customers being managed by WMBC which doesn’t have a dedicated CRM role.

These updates and amendments will apply from the date of publication.

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