The Senior Accounting Officer Requirement
22 October 2009 by Kimberley Britt
Is your company prepared?
Driven by HM Revenue & Customs desire to push responsibility for the accuracy of tax onto the Boardroom agenda, the recent Budget announcement in April 2009 has resulted in the requirement that the ‘Senior Accounting Officer’ of qualifying companies (and their subsidiaries) must demonstrate that they have taken ‘reasonable steps’ to ensure that ‘appropriate accounting arrangements’ are in place.
So what does this mean in real terms for the SAO?
The main duties of the SAO are to demonstrate that ‘reasonable steps’ have been taken to establish and maintain appropriate tax accounting arrangements. The arrangements must then be monitored and any areas of non-compliance must be identified.
At the end of the period for filing accounts for the end of the financial year, the SAO must provide a certificate to HMRC stating that the company and all its subsidiaries had appropriate tax accounting arrangements, or, where appropriate arrangements have not been in place, an explanation for this must be given.
HMRC are adamant that these new rules are not intended to, and critically must not, create a significant burden for companies that already have adequate systems in place. So if your company is contemplating or has already been advised to implement costly and time consuming measures to comply with the rules, we wold like to offer you a more cost effective alternative.
Pure have a straight forward solution that implements ‘appropriate accounting arrangements’ only where needed and demonstrates that ‘reasonable steps’ have been taken. Our solution gives the SAO and Tax Directors peace of mind and a process which can be signed off in a cost effective way.
How we can assist your company
Methodology
In order to help you to develop a practical and cost-effective strategy for complying with the SAO rules, our simple approach involves the following steps:
- An initial discussion to understand your existing approach to tax strategy, your resource levels and existing areas of tax risk. Unlike normal costly reviews this will be based on your existing knowledge and does not require us to duplicate work you have already done or knowledge that already exists.
- Bring pre-populated and established draft systems diagrams, process documents and policies that can be tailored to your organisations existing processes. Again this removes the duplication from a ’start from scratch’ approach.
- Critically, we will deliver process documents that establish ownerships within your organisation that can be signed off at the relevant departmental level before being approved by the Tax Director and ultimately the SAO.
This approach means that you take what you already know about your organisation and use it to fit in with a developed system. This means the volume of work needed from both sides is minimised while satisfying the SAO rules.
The benefits of our approach
Pure Interim can offer your company a cost effective solution to the SAO Requirement. Our team of tax professionals will identify any tax risks and establish effective key processes and controls.
With a flexible approach, our team of integrated specialists can assist your company to become compliant on a project, contract or temporary basis giving you maximum control over this task without handing it over to outside firms.
We can provide your company with access to consultants with backgrounds in Big 4 accounting firms, further enhanced by extensive in-house experience within the management of tax and risk assurance and offering solid tax technical expertise within each affected tax specialism.
Our consultants are employed by Pure, not by your company and charged out at hourly or daily rates therefore offering greater fl exibility and simplicity. Hourly or daily rates are significantly lower than those akin to their equivalent counterpart from a Big 4 Accounting firm (please contact us for specific quotes).
Tax Risk Management Specialist
A Corporate Tax Consultant/Director, ACA & ACT qualified, having most recently worked for two major Blue-Chip companies after training with a Big 4 Firm. Specialist areas include leading the group’s tax risk management strategy, managing the tax reporting and compliance process and leading a major review undertaken by HMRC of the group’s systems and processes. This individual will add value to any organisation through his strengths in project management, problem analysis and solution and his attention to detail covering all aspects of a process.
Corporate Tax Specialist
Senior Tax Manager, CTA qualified, who spent the 10 years working at a Big 4 Firm and prior to that at an international financial services group. This individual has experience of managing a large and varied portfolio of clients in the consumer and industrial markets sector. Her areas of expertise include running large tax outsourcing projects, tax audits and compliance as well as project management. This individual has excellent
communication skills combined with a pro-active approach and an ability to work to deadlines.
VAT Specialist
Senior VAT Manager with experience working at a Big 4 Firm and in the commercial sector, primarily within the technology and manufacturing sectors. Previous experience of managing the VAT compliance and reporting process, systems implementation, providing VAT advisory services to the operating
businesses and policy discussions with Customs & Excise. A confident communicator who enjoys challenges and takes satisfaction in finding new ways to improve efficiency as well as having a pragmatic approach to dealing with issues.
PAYE Specialist
An Employment and Expatriate Tax specialist with experience of working in industry for three FTSE100 employer’s, over ten years experience of working within two ‘Big 4’ Accountancy firms plus nearly eight years with HM Revenue & Customs (HMRC). His key areas of expertise include PAYE/NIC audits, Expatriate UK Employer Tax and Social Security compliance, PAYE Dispensations and establishing a new process for the completion of P11Ds. This individual is extremely effective at ‘fixing’ tax problems and finding practical and cost effective solutions to employer tax compliance issues.
Contact Kimberley Britt to find out more
Kimberley Britt
Executive Consultant
Kimberley joined Pure in April 2007. Her principal focus is the placement of tax professionals into temporary and contract assignments within Commerce and Industry and Professional Services. Kimberley’s remit also extends to interim Employment & Expatriate tax placements. Kimberley’s direct line: 020 7429 4425 kimberleybritt@pureinterim.com
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