SAO Tax Diary

SAO Tax Diary

Our tax governance team brings you regular insights, updates and opinions on all matters concerning the SAO Regulations, tax strategies and other developments in tax governance.

Director, Head of Tax Governance for National Markets

KPMG in the UK


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KPMG in the UK’s SAO Tax Diary page brings you regular insights, updates and opinions on all matters concerning Senior Accounting Officer and wider tax governance. Hosted by Chris Downing, Head of Tax Management Consulting, and Peter Honeywell, Head of Tax Governance for National Markets, the page considers issues arising from the introduction of relevant legislation and guidance, as well as providing updates concerning the way that this is being both implemented in practice and approached by HMRC.

Recent updates to the page include:

Tax Strategies: HMRC Guidance

HMRC have now issued further guidance concerning the requirement that large corporates should publish their tax strategies. This remains in draft and is likely to take some time to be finalised. Nevertheless, we already know that the overwhelming majority of groups that are currently within the SAO regime will be affected, both UK-owned groups and the UK sub-groups and subsidiaries of foreign parents, together with partnerships and UK Permanent Establishments (PEs) of an equivalent size.

‘SAO main duty – what does good compliance look like and how is it delivered’ – HMRC’s view

Following consultation with advisors, HMRC have now produced the attached summary of its expectations with regard to compliance with the requirement that SAOs should take ‘reasonable steps to ensure that the company establishes and maintains appropriate tax accounting arrangements’ (Para 1 Sch 46 FA2009). This will be rolled out to Customer Relationship Managers (CRMs) during 2016/17. The issue of this new document is consistent with HMRC refocusing on the ‘main duty’ requirement of the legislation, including the effectiveness of monitoring activities.

If you would like to receive regular updates on the SAO Tax Diary and SAO Forum activity, please subscribe to with your name, job title, company name and email address.

For further information please contact :

Chris Downing 

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