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HMRC’s Revenue & Customs Brief 16/12 refreshes the guidance concerning the application of the senior accounting officer (SAO) rules.
The main changes include the following points.
With regard to insolvency procedures, HMRC have decided that the rules apply in most cases where such procedures are underway.
The turnover test for banks and insurance companies has been revised to the extent that the word ‘turnover’ must take its meaning from the Companies Act definition, and the turnover test should be applied to all companies including banks and insurance companies.
HMRC no longer believe that companies are only within the SAO rules in relation to their UK activities.
Finally, no confidentiality/disclosure bars prevent the disclosure of a late or the non-provision of an SAO certificate to a company.
HMRC will not consider charging penalties where companies and SAOs have followed previous guidance for any period up to the first period beginning after the publication of this revised guidance.
Additionally, HMRC intend to operate a ‘light touch’ period to any companies that are brought into the SAO regime by the changed interpretation for the same period. Penalties will not be charged for previous periods where one would seem to be due under the previous guidance, but which would not be due under the revised guidance.
