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Review of HMRC’s SAO guidance manual

The Senior Accounting Officer (SAO) legislation was introduced in 2009 (FA 2009 Sch 46) with effect for financial years commencing on or after 21 July 2009. These rules require a senior finance officer typically the Finance Director to personally ensure and certify that the companies for which he or she is responsible have appropriate processes and systems for calculating UK taxes and duties. In the period since its announcement many SAOs and their tax teams have expressed concern over the practical application of the legislation particularly in light of its subjective nature and personal impact.

On 26 April 2012 HMRC issued revised SAO guidance for its staff and made this available publically. The guidance has been largely well received as it:

  • confirms three shifts in policy;
  • provides greater clarity on areas of practical uncertainty; and
  • seeks to explore some...

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