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Official guidance
Senior Accounting Officer Guidance

SAOG14400 · Senior Accounting Officer main duty: reasonable steps

  • SAOG14410 · What are reasonable steps
  • SAOG14420 · Establishing and maintaining processes
  • SAOG14430 · Monitoring processes
  • SAOG14440 · Considering opening balances and standing data
  • SAOG14450 · Example of standing data
  • SAOG14460 · Making delegations
  • SAOG14465 · VAT representative company
  • SAOG14470 · Making outsourcing arrangements
  • SAOG14480 · Making tax sensitive judgements
  • SAOG14490 · Examples of tax sensitive judgements
  • SAOG14500 · Where mergers and acquisitions occur
  • SAOG14510 · Example 1 - Shared Service Centre
  • SAOG14511 · Example 2 - Retailer and VAT codes
  • SAOG14512 · Example 3 - Customs data on import and export declarations
  • SAOG14513 · Example 4 - Customs Freight Simplified Procedures
  • SAOG14514 · Example 5 - reasonable steps that vary across taxes
  • SAOG14515 · Example 6 - takeover or merger
  1. Senior Accounting Officer main duty: reasonable steps: contents
  2. Senior Accounting Officer main duty: reasonable steps: establishing and maintaining processes

SAOG14420 | Senior Accounting Officer main duty: reasonable steps: establishing and maintaining processes

From HM Revenue & Customs · Senior Accounting Officer Guidance

Qualifying companies are large businesses. All have processes to support tax accounting. Some of these may have been in place for a long time.

A Senior Accounting Officer (SAO) must consider, as part of the reasonable steps they take, whether existing processes within the tax accounting arrangements are sufficiently robust such that any inaccuracy in a return or document containing figures arising from any of those processes would be unlikely to result in a liability to any penalties under tax law.

An SAO must also consider how the company should maintain the existing processes, and whether it may need to enhance those processes or replace them with an alternative.

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