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The SAO toolkit

Ready, Steady, Sign

The SAO toolkit  

Download Beyond year 1: The SAO Toolkit Download Beyond year 1: The SAO Toolkit (PDF, 839 KB) looks back at what we’ve learnt in the three years since SAO was announced and considers what SAOs and businesses should be doing in order to be compliant with the legislation in years two and beyond.

SAO Toolkit The SAO Toolkit (PDF, 1.13 MB) has been developed to give you practical guidance on immediate areas of focus, common risk areas, getting the documentation right, the on-going monitoring and assurance needed, and more.


Under the Senior Accounting Officer (SAO) legislation, introduced in 2009, the individual responsible is required to personally certify that their company systems are fit for the purpose of reporting taxes.  Revised guidance from HMRC was issued on 26 April 2012 on the practical application of the Senior Accounting Officer.

The revised guidance is positive news for 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 might be levied.  

All SAOs should now have submitted their first certificate and, based on our data, it would appear that around 30% have disclosed errors or weaknesses in their UK tax controls.  This new guidance comes at a time when the initial “light touch” period no longer generally applies and will be well received as companies , more than ever, need to understand how HMRC intends to apply the legislation.

Key findings

  • How have companies responded to SAO?
  • Common areas of risk
  • If you do nothing else before submitting the certificate...
  • The SAO Certificate - what you may wish to include and how much to disclose
  • Beyond year one - ongoing monitoring and assurance
  • Getting the documentation right
  • Engaging with HMRC
  • In all material respects?
  • The interaction with other regimes – the view from Counsel
  • Appendices: The Corporate Tax, Employment Tax, VAT and Customs perspectives


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