International Tax Review is part of the Delinian Group, Delinian Limited, 8 Bouverie Street, London, EC4Y 8AX, Registered in England & Wales, Company number 00954730
Copyright © Delinian Limited and its affiliated companies 2023

Accessibility | Terms of Use | Privacy Policy | Modern Slavery Statement

HMRC confirms that transfer pricing documentation is covered by the senior accounting officer regime

In the UK, companies or groups with turnover over £200 million ($300 million) and / or a balance sheet total over £2 billion in the preceding accounting period must appoint a senior accounting officer (SAO).

The SAO is the director, or officer, who has overall responsibility for the company's financial accounting arrangements. The company must tell HM Revenue & Customs (HMRC) who the SAO is, and the SAO will have personal responsibility for confirming that the company establishes and maintains appropriate tax accounting arrangements by issuing a certificate to HMRC by a prescribed deadline.

Failure to do so can result in penalties for the company and the SAO personally. The regime was first introduced for accounting periods beginning on or after July 21 2009 with a light touch approach in the first year under the rules. However for many companies this light touch period has come to an end.

For the purposes of the SAO rules, HMRC views tax accounting arrangements as the framework, responsibilities, policies, appropriate people and procedures in place for managing tax compliance risk and the systems and processes for putting this framework into practice.

HMRC has also recently issued updated guidance and, whilst the guidance does not specifically mention transfer pricing as being part of a company's financial accounting arrangements, HMRC has just confirmed, in correspondence, that it does consider that transfer pricing is included.

Therefore, any decisions or calculations made in respect of transfer pricing adjustments will come within the scope of the SAO rules, regardless of whether they are embedded within the company's accounting system or not.

By principal correspondents for TP Week in the UK, Yvonne Chappell (, Lorna Smith ( and Gillian Kidd ( , of Grant Thornton UK LLP.

more across site & bottom lb ros

More from across our site

Governments now have the final OECD guidance on how to implement the 15% global minimum corporate tax rate.
The Indian company, which is contesting the bill, has a family connection to UK Prime Minister Rishi Sunak – whose government has just been hit by a tax scandal.
Developments included calls for tax reform in Malaysia and the US, concerns about the level of the VAT threshold in the UK, Ukraine’s preparations for EU accession, and more.
A steady stream of countries has announced steps towards implementing pillar two, but Korea has got there first. Ralph Cunningham finds out what tax executives should do next.
The BEPS Monitoring Group has found a rare point of agreement with business bodies advocating an EU-wide one-stop-shop for compliance under BEFIT.
Former PwC partner Peter-John Collins has been banned from serving as a tax agent in Australia, while Brazil reports its best-ever year of tax collection on record.
Industry groups are concerned about the shift away from the ALP towards formulary apportionment as part of a common consolidated corporate tax base across the EU.
The former tax official in Italy will take up her post in April.
With marked economic disruption matched by a frenetic rate of regulatory upheaval, ITR partnered with Asia’s leading legal minds to navigate the continent’s growing complexity.
Lawmakers seem more reticent than ever to make ambitious tax proposals since the disastrous ‘mini-budget’ last September, but the country needs serious change.