SAOG15400 - Senior Accounting Officer must provide a certificate to HMRC: specimen qualified certificate

The Senior Accounting Officer (SAO) will provide a qualified certificate where they are certifying that the company did not have appropriate tax accounting arrangements throughout the financial year.

A suggested format for the qualified certificate is

‘In accordance with Paragraph 2 Schedule 46 Finance Act 2009 I ……………………………………… as Senior Accounting Officer of the qualifying company listed below, hereby certify that, throughout the company’s financial year ended …………………………… the company did not have appropriate tax accounting arrangements’.

The respects in which the accounting arrangements of the company/companies were not appropriate tax accounting arrangements are as follows.

Name of Company	UTR	Explanation

The legislation does not specify the level of detail to be included in the explanation on the certificate. However, we would expect to see a summary of the reasons that led to the SAO’s decision to provide a qualified certificate to allow the Customer Compliance Manager (CCM) or the Mid-sized Business Customer Engagement Team (CET) to understand in what respects the tax accounting arrangements were inappropriate. It should not be simply a statement of an error or a list of errors but should explain what the shortcomings were in the accounting arrangements that led to the error(s). CCMs or the CET should encourage the SAO to discuss any areas of doubt about the level of detail required with them.

There is no legal requirement for the certificate to contain remediation plans. However it is very likely that HMRC will make enquiries about any highlighted weaknesses or failure. As such HMRC has no objection if SAOs decide to pre-empt such enquiries by giving an unsolicited explanation of remediation plans either in or alongside the certificate.

The certificate must be signed and dated by the SAO.

See SAOG15200 for guidance on what an SAO should do in respect of a period within a financial year before they became the SAO, and what they should take into account when considering their certificate for that financial year.

In the case of a liquidation or administration, see SAOG15200, where the SAO has succeeded to this role on or after the date of liquidation/administration and they are unable to provide an unqualified certificate the form of words above would be slightly amended as follows:

‘In accordance with Paragraph 2 Schedule 46 Finance Act 2009 I ……………………………………… as Senior Accounting Officer of the qualifying company listed below, hereby certify that, throughout the company’s financial year ended …………………………… the company did not have (may not have had) appropriate tax accounting arrangements’.

The respects in which the accounting arrangements of the company was not (or may not have been) appropriate tax accounting arrangements are as follows.

Name of Company	UTR	Explanation
	I became SAO of this Company on [date of appointment], following the company’s entry into liquidation / administration. I am unable to present a (complete) view as to the appropriateness or otherwise of the systems used by the company prior to this date. It is not within my mandate as part of the liquidation or administration to make an investigation to establish the situation prior to my appointment for these purposes
	SAO to enter here and in as many further boxes as necessary explanations about inappropriate tax accounting arrangements prior to the liquidation / administration of which they are aware and explanations about all accounting arrangements which were not appropriate tax accounting arrangements following the liquidation / administration

If a person is providing the SAO certificate for more than one company they may if they wish provide one or more combined certificates - see SAOG15500.