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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: where mergers and acquisitions occur

SAOG14500 | Senior Accounting Officer main duty: reasonable steps: where mergers and acquisitions occur

From HM Revenue & Customs · Senior Accounting Officer Guidance

A company that is merged or acquired retains its qualifying or non-qualifying status for its financial year in which it was acquired.

It can only change its status for the following financial year at the earliest. As such a merger or acquisition is no different in effect to a company that changes its status as a result of, say, an increase or decrease in turnover and/or balance sheet assets.

In the case of the merger or acquisition of a non-qualifying company that becomes a qualifying company from the start of the following financial year, the Senior Accounting Officers (SAO’s) responsibility in relation to the main duty only commences on the first day of that following financial year.

We recognise that following a takeover or merger it may take some time for a new SAO to make any changes that are necessary in order to bring accounting arrangements up to the required level. These circumstances will be taken into account in considering what constitutes ‘reasonable steps’ including the time scale over which the changes are made in relation to the issues encountered.

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