SAO regime: penalties and pitfalls

It is now nearly six years since HMRC introduced legislation (FA 2009 Sch 46) requiring the senior accounting officers (SAOs) of large corporates to report on the appropriateness of their tax accounting arrangements. HMRC’s position on this legislation has moved from the ‘light touch approach’ it adopted in year one to an increasingly more proactive and challenging stance. In line with this approach penalties chargeable under the legislation are now being more regularly applied. Our experience to date has shown that a number of common circumstances are leading to the penalties being levied. In this article...