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Senior Accounting Officer sign-off

Taking reasonable steps

The SAO legislation was introduced in the 2009 Budget and requires the nominated SAO within a company to ensure that the company establishes and maintains appropriate tax accounting arrangements. For SAOs and those briefing SAOs a clear strategy must put in place to ensure compliance. The legislation puts tax firmly on companies’ agendas, creating an impetus for many to improve and transform the way in which they manage tax.

HMRC released revised guidance to support the Senior Accounting Officer regime on 26 April 2012. The revised guidance is positive news for both SAOs and their companies as it provides greater clarity around some of the more challenging aspects of the rules, including the circumstances in which penalties may or may not be levied.

Latest HMRC guidance released, 26 April 2012

The SAO Toolkit

Beyond year one: The SAO Toolkit   Beyond year one: The SAO Toolkit
We looked back at what we’ve learnt since the three years since SAO was introduced and looking forward , we considered what SAOs and businesses should be doing in order to be compliant in years two and beyond.
Ready, Steady, Sign – The SAO Toolkit   Ready, Steady, Sign – The SAO Toolkit
Our practical guide to help you prepare for the submission of the Senior Accounting Officer certificate, for year one and beyond.


  SAO-engage your regulator
The reactions that Deloitte has seen from both business and HMRC to the legislation and how engaging with your CRM should form a fundamental part of your response.
SAO: The latest views   SAO: The latest views
The latest views on SAO from HMRC and business.

Compliance and Tax transformation for companies affected by the SAO legislation

Senior Accounting Officer Rules   Senior Accounting Officer Rules - Sign-off, Sign-on or Sign-out?
How the SAO legislation impacts employers with an internationally mobile workforce.
  Enabling excellence in tax processes - what good looks like (PDF, 609 KB)
Best practice tax management in the context of the SAO legislation.

Getting the documentation right

  What do I do now? (PDF, 3907 KB)
With the SAO legislation in place, what steps should those with responsibility for tax in qualifying companies be taking now to achieve compliance?
  Senior Accounting Officer sign off – the draft guidance
Does it square the circle? (PDF 33 KB)
Does the guidance assist businesses in implementation of a high impact policy in a low impact way?
  Senior Accounting Officers for Large Companies: Technical Update 3 July 2009 (PDF, 53 KB)
Our summary of the latest version of the draft legislation and its draft accompanying guidance.
Deloitte Image   Senior Accounting Officer accountability survey
Tax and finance professionals' views on the proposed legislation.
Deloitte Image   Senior Accounting Officer sign-off: what does it mean in practice? 
Our latest insights from the consultation process and House of Commons Debate on the SAO measure.
Deloitte Image   Tax Accounting Systems - take reasonable steps now
Alan MacPherson, Deloitte partner, presents on the SAO measure and its practical implications for companies. The deck includes updates following the House of Commons debate held on 13 May.

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