Getting the documentation right
Although there is no specific requirement under the SAO regime to produce process or control documentation, we are seeing it being increasingly developed by those responsible for taxes to improve or evidence controls and also protect against dependency on key individuals. However, before creating masses of documentation it is important to ensure that it achieves the goal of supporting compliance without becoming an unnecessary burden or, at worst, a risk in itself. To get the right balance, we would suggest bearing in mind the following Do’s and Don’ts.
- Think about the target user/audience for the documentation as this will determine the style and content. For example, is the user a corporate tax specialist who needs to focus on key tax risks and historic positions or a finance assistant who needs more detailed guidance around the VAT return process?
- Ensure that the documentation fits with existing materials, group policies and procedures so that, for example, statements around risk appetite are consistent with group level statements.
- Make sure the team are aware of the importance of the guidance and that the latest version is readily available to users. One way of doing this is having a launch event sponsored by the SAO and then publishing the guidance on a website and tasking someone with making sure it is regularly checked as being up to date.
- Don’t produce materials that are unwieldy and unlikely to be used or likely to become rapidly outdated. Documentation is just one piece of the puzzle - it doesn’t constitute appropriate arrangements in itself. For example, you would also need to consider whether you have appropriately trained and experienced staff in place using the guidance as well as potentially periodically testing adherence with policy.
- Don’t miss the opportunity when documenting existing tax accounting arrangements to identify efficiencies/improvements in the current processes.