SAO guidance

HMRC has confirmed in Revenue and Customs Brief 12/2016 that it will now accept certificates from a company’s senior accounting officer (SAO) in any recognised paper or electronic format, including letter, fax or email. See www.bit.ly/1UEeNfz. Certificates provided before the publication of this change will only be valid if they meet the previous requirements for original, signed, paper certificates. This, together with a number of other administrative changes, are set out in updates to the SAO guidance manual published on 13, 19 and 23 May 2016. See www.bit.ly/25LDoEg.

Other changes that clarify existing practices include:

·        where a newly-incorporated company (or a company whose turnover and/or balance sheets are below qualification level) joins a group;

·        addition of Industrial and Provident societies and Cooperative and Community Benefit Societies to the list of non-qualifying bodies;

·        HMRC’s view that the SAO role can’t be delegated to an agent or adviser of the company;

·        HMRC’s view that certificates for short and long accounting periods should match the Companies House filing period;

·        HMRC’s view that a SAO is still responsible for outstanding certificates when a company is struck off;

·        requests for time extensions must still allow sufficient time for HMRC to receive, consider and provide a response;

·        organisational change within HMRC and the role of wealthy and mid-size business compliance; and

·        confidentiality procedures when gathering information or discussing issues with a company around personal penalties for SAOs and additional information on the detail to be included in penalty notices.