SAOG15100 - Senior Accounting Officer must provide a certificate to HMRC: overview

A Senior Accounting Officer (SAO) must provide a certificate to HMRC after the end of a financial year of a qualifying company.

In the certificate an SAO must state that either

  • the company had appropriate tax accounting arrangements throughout the financial year, or
  • the company did not have appropriate tax accounting arrangements throughout the financial year and give detail about the respects in which the arrangements were not appropriate.

The certificate will extend to any activities carried out by other parties as part of the company’s tax accounting arrangements that will impact on the calculation of the company’s relevant liabilities, see SAOG14335, SAOG14465 and SAOG14470.

An SAO must provide a certificate for each financial year that the company is a qualifying company. They can include more than one company for which they were SAO on a certificate.

An SAO must give HMRC the certificate before the end of the period that the company has after the end of its financial year for filing its accounts with Companies House or at any later time as allowed by HMRC.

Customer Compliance Managers (CCMs) or the Mid-sized Business Customer Engagement Team (CET) should be sympathetic to requests on rare occasions for short extensions to the date for providing the certificate, see SAOG15700. However this should not become an expectation on behalf of the SAO. CCMs or the CET must certainly not allow extensions as a matter of course. CCMs or the CET must not allow more time simply because the financial years of group companies do not end on the same day.

If an SAO fails to provide the certificate by the end of the allowed period, they will be liable to a penalty, see SAOG18500, unless they have a reasonable excuse, see SAOG20000.

If an SAO provides a timely certificate that contains a careless or deliberate inaccuracy, they will be liable to a penalty, see SAOG18600.

FA09/SCH46/PARA2