SAOG15500 - Senior Accounting Officer must provide a certificate to HMRC: Person is SAO for more than one company

A person may be the Senior Accounting Officer (SAO) for more than one company. This is most likely but not exclusively where the companies are within a group. In such cases the SAO must certify the appropriateness of the tax accounting arrangements for each of the companies for which they are the SAO.

To do this the SAO can provide

  • a separate certificate for each company, or
  • a certificate covering all the companies, or
  • a combination of certificates.

For example, in the case of companies A, B and C for which the same person is SAO, the SAO could provide

  • a separate certificate for each of companies A, B and C, or
  • a separate certificate for A and a combined certificate for B and C (or any other permutation), or
  • a single certificate for all three companies.

Using such combinations will be useful where some or all of the companies for which a person is SAO have differing financial year ends. If an SAO submits a single certificate for a number of companies that have differing year ends the certificate must be submitted in accordance with the time limit relating to the company with the earliest year end.

Where they fail to do so, a penalty position will arise in respect of any company for which the certificate is late but this will not necessarily be all the companies on the certificate. To avoid this penalty position, the SAO might submit a certificate for the company/ companies with an early financial year end but then submit a separate certificate for the company/ companies with the latest financial year ends.

SAOG15200 provides guidance on what an SAO must certify to HMRC.

The appropriate wording where the tax accounting arrangements in all the companies are appropriate may be found in the specimen unqualified certificate at SAOG15300, subject to any amendments required to reflect that the certificate covers more than one company.

The appropriate wording where the tax accounting arrangements in all the companies are not appropriate may be found in the specimen qualified certificates at SAOG15400, subject to any amendments required to reflect that the certificate covers more than one company.

However, if an SAO is responsible for several companies and for some of those the tax accounting arrangements are appropriate but for others they are not, an SAO may still submit a combined certificate. A suggested format for the certificate is:

‘In accordance with Paragraph 2 Schedule 46 Finance Act 2009, I…………………………………… as Senior Accounting Officer hereby certify, in respect of the financial year ended state that: the following companies had appropriate tax accounting arrangements throughout the year’.

Name of Company Financial Year End UTR
     
     

the following companies did not have appropriate tax accounting arrangements and I provide an explanation of the respects as to why this was the case in relation to each company.

Name of Company Financial Year End UTR Explanation