SAOG15400 - Senior Accounting Officer must provide a certificate to HMRC: specimen qualified certificate
The Senior Accounting Officer (SAO) will provide a qualified certificate where they are certifying that the company did not have appropriate tax accounting arrangements throughout the financial year.
A suggested format for the certificate is
‘In accordance with Paragraph 2 Schedule 46 Finance Act 2009 I ……………………………………… as Senior Accounting Officer of the qualifying company/ companies listed below, hereby certify that, to the best of my knowledge and belief, throughout the company’s/ companies’ financial year ended …………………………… the company/ companies did not have appropriate tax accounting arrangements.
The respects in which the accounting arrangements of the company/companies were not appropriate tax accounting arrangements are as follows.
| Name of Company | UTR | Explanation |
In the case of a liquidation or administration, see SAOG15200, where the SAO has succeeded to this role on or after the date of liquidation/administration and they are unable to provide an unqualified certificate the form of words above would be slightly amended as follows:
‘In accordance with Paragraph 2 Schedule 46 Finance Act 2009 I ……………………………………… as Senior Accounting Officer of the qualifying company/ companies listed below, hereby certify that, to the best of my knowledge and belief, throughout the company’s/ companies’ financial year ended …………………………… the company/ companies did not have (may not have had) appropriate tax accounting arrangements.
The respects in which the accounting arrangements of the company/companies were not (or may not have been) appropriate tax accounting arrangements are as follows.
| Name of Company | UTR | Explanation |
| I became SAO of this Company on [date of appointment], following the company's entry into liquidation / administration.I am unable to present a (complete) view as to the appropriateness or otherwise of the systems used by the company prior to this date. It is not within my mandate as part of the liquidation or administration to make an investigation to establish the situation prior to my appointment for these purposes | ||
| SAO to enter here and in as many further boxes as necessary explanations about inappropriate tax accounting arrangements prior to the liquidation / administration of which they are aware and explanations about all accounting arrangements which were not appropriate tax accounting arrangements following the liquidation / administration |
The legislation does not specify the level of detail to be included in the explanation on the certificate. However, by the very fact that a qualified certificate is being submitted the SAO must have undergone a thought process to arrive at the decision that he has to provide a qualified certificate. A crystallised explanation of this process would therefore be a good template for the SAO to work to. It must provide sufficient detail to allow the Customer Relationship Manager (CRM) to understand in what respects the accounting arrangements were inappropriate.
There is no legal requirement for the certificate to contain remediation plans. However it is very likely that HMRC will make enquiries about any highlighted weaknesses or failure. As such HMRC has no objection if SAOs decide to pre-empt such enquiries by giving an unsolicited explanation of remediation plans either in or alongside the certificate.
The certificate must be signed and dated by the SAO.
