Penalties for senior accounting officer regime failures

Castlelaw was part of a group of companies. Although it was dormant and had no tax liabilities it was a qualifying company for the senior accounting officer regime because it was a member of a larger group of companies. Mrs Douglas was the senior accounting officer for 33 of the companies in the group - including Castlelaw - and also the group company secretary.

In 2016 a group structure chart sent to HMRC as part of a business risk review omitted Castlelaw. When this was pointed out Mrs Douglas said she had done this ‘inadvertently’.

However the company and its senior accounting officer were liable to a penalty and because the rules allow only one of each type of penalty for a group a year HMRC assessed a £5 000 penalty on Castlelaw for failing to name its senior accounting officer and another £5 000 penalty...