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Senior Accounting Officer

Approaches to the Senior Accounting Officer (SAO) regime have evolved since its introduction, driven by improvements in guidance from HMRC and best practice from larger companies.

Using this best practice to move your SAO approach beyond compliance can add real value to your business.

Who does SAO apply to?

The SAO rules apply to UK companies who either alone, or when aggregated with other UK companies within their group, have a turnover in excess of £200 million and/or a balance sheet total in excess of £2 billion. All such companies must appoint a director or officer who, in the company’s reasonable opinion, has overall responsibility for the company’s financial accounting arrangements. Failure to provide the SAO certificate or maintain appropriate tax accounting arrangements may lead to separate penalties of £5,000 being levied on the SAO personally.

How to gain value from the Senior Accounting Officer process

When the SAO rules were first introduced in 2009, they were regarded by many as simply another administrative burden - a further drain on time and money for no measurable benefit. This perception, combined with HMRC’s propensity to issue penalties for administrative failures with limited scope for mitigation, has prompted many businesses to approach compliance as a ‘tick box’ exercise. But added to other commitments such as Business Risk Review (BRR+), SAO can be a tool to drive behavioural change in a business: enhancing compliance and ensuring greater transparency in relationships with HMRC, shareholders and consumers.

In our experience, companies who have approached their SAO obligations seriously and strategically are realising the value of taking a close look at their business processes and tax controls. They are not only learning more about the workings of their business, but they are also unlocking enhanced efficiency across their operations and tax function, as well as identifying cost savings.

Failure to comply can impact a company’s risk rating, as well as its reputation with the public and stakeholders. HMRC continues to demand good tax governance from businesses of all sizes.

How we can we help?

Good tax governance is driven from the top. That’s why our tax risk management team is comprised of senior members of our organisation with years of experience in tax compliance - bringing commercial insight and sector experience to your SAO processes.

We can:

  • conduct strategic workshops with your senior people to understand your business strategy and culture, and how this fits with your tax control frameworks
  • involve our sector experts to understand risks and opportunities unique to your industry
  • work with your finance and tax teams to identify areas of greatest tax risk for review, strategically focusing on these risk areas
  • use your strengths and existing processes. We're not trying to reinvent the wheel. We will seek to leverage existing documentation and controls across the finance function, eg - manuals, The Sarbanes–Oxley Act (SOX) controls and internal audit documentation.
  • revisit existing controls with a fresh pair of eyes and challenge whether these are relevant, complete, consistent, robust and not duplicated
  • focus on whether each control is clearly defined, so that it can be articulated, understood, tested and then measured going forward
  • consider whether controls have kept up with the pace of external changes and new legislation (eg, IR35, Making Tax Digital, Country-by-Country Reporting and BEPS)
  • review any recent transformational change in relation to the business’s finance or tax functions, as well as any new technology or processes that may be tax sensitive
  • ensure owners of current processes and controls are appropriate and consider recent or upcoming people changes
  • where errors have occurred, support you in taking remedial action, including disclosure and ensuring the same errors do not occur again
  • identify opportunities for process improvement, cash flow savings and tax efficiencies.

Even if your business is not currently within SAO but may soon breach the threshold, our team will make sure that you are prepared and your relevant processes and controls are understood and fit-for-purpose.


Lee Holloway

+44 (0)20 7728 2650

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