Jason Land and Laura Harper (BDO) examine HMRC’s updated guidance on SAO qualifying businesses.
On 25 March this year HMRC updated its Senior Accounting Officer Guidance Manual. Some of these changes were simple updates designed to ease elements of the administrative burden of compliance. But more significantly the updates also included a new policy (and some practical examples) on circumstances where HMRC may exercise discretion in the issuing of SAO penalties this new policy driven by the dismissal at the First-tier Tribunal (FTT) of the Castlelaw (No. 628) Ltd & another v HMRC [2020] UKFTT 34 (TC) (Castlelaw).
The Castlelaw case
Castlelaw (No. 628) Ltd (‘Castlelaw’) was a member of a group of more than 100 companies which had been SAO qualifying since the introduction of the legislation. Despite previously having been included on the group’s SAO submissions it had been mistakenly omitted for the submission made...
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Jason Land and Laura Harper (BDO) examine HMRC’s updated guidance on SAO qualifying businesses.
On 25 March this year HMRC updated its Senior Accounting Officer Guidance Manual. Some of these changes were simple updates designed to ease elements of the administrative burden of compliance. But more significantly the updates also included a new policy (and some practical examples) on circumstances where HMRC may exercise discretion in the issuing of SAO penalties this new policy driven by the dismissal at the First-tier Tribunal (FTT) of the Castlelaw (No. 628) Ltd & another v HMRC [2020] UKFTT 34 (TC) (Castlelaw).
The Castlelaw case
Castlelaw (No. 628) Ltd (‘Castlelaw’) was a member of a group of more than 100 companies which had been SAO qualifying since the introduction of the legislation. Despite previously having been included on the group’s SAO submissions it had been mistakenly omitted for the submission made...
If you or your firm subscribes to Taxjournal.com, please click the login box below:
If you do not subscribe but are a registered user, please enter your details in the following boxes:
