The SAO of a qualifying company must provide HMRC with a certificate (for each financial year) stating whether the company has appropriate tax accounting arrangements or, where it does not, providing an explanation.
For VAT, the tax accounting arrangements in scope would be those that:
- Produce any numbers or figures feeding through into the VAT returns for the year.
- Any of the 2010 tax accounting arrangements that have an impact on the VAT figures for a period falling partly in 2009.
- Any of the 2010 tax accounting arrangements that have an impact on earlier financial years i.e. where there is a review of historic returns for voluntary disclosure purposes.
The SAO can be selected from the worldwide group of companies and will not necessarily be an officer /director of any of the UK group companies. However, they are likely to be the person or persons who have de facto overall responsibility for financial accounting arrangements for the UK companies. The SAO would have responsibility for providing the certificate and should understand that SAO penalties do not relate to each company but to the SAO themselves.
KPMG has experience of end-to-end technology and process reviews focusing on assisting senior finance officers with SAO regime readiness. A team of cross-discipline specialists will focus their energies on the following areas over the course of the review:
- Reviewing the overall governance framework for the manager of tax risk.
- Risk assessment to determine inherent risk of tax being incorrectly accounted for.
- Review of existing process and controls to see how effective they are in managing tax risk, and making recommendations to improve.
- Implemented control activities to mitigate identified risks.
- Review monitoring activities and level of independent assurance.
Are you ready to challenge assumptions around the integrity of your business systems?
