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

International Tax Review is part of Legal Benchmarking Limited, 1-2 Paris Garden, London, SE1 8ND

Copyright © Legal Benchmarking Limited and its affiliated companies 2026

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 (yvonne.chappell@uk.gt.com), Lorna Smith (lorna.smith@uk.gt.com) and Gillian Kidd (Gillian.kidd@uk.gt.com) , of Grant Thornton UK LLP.

more across site & shared bottom lb ros

More from across our site

Overall revenues for the combined UK and Swiss firm inched up 2% to £3.6 billion despite a ‘challenging market’
In the first of a two-part series, experts from Khaitan & Co dissect a highly anticipated Indian Supreme Court ruling that marks a decisive shift in India’s international tax jurisprudence
The OECD profile signals Brazil is no longer a jurisdiction where TP can be treated as a mechanical compliance exercise, one expert suggests, though another highlights 'significant concerns'
Libya’s often-overlooked stamp duty can halt payments and freeze contracts, making this quiet tax a decisive hurdle for foreign investors to clear, writes Salaheddin El Busefi
Eugena Cerny shares hard-earned lessons from tax automation projects and explains how to navigate internal roadblocks and miscommunications
The Clifford Chance and Hyatt cases collectively confirm a fundamental principle of international tax law: permanent establishment is a concept based on physical and territorial presence
Australian government minister Andrew Leigh reflects on the fallout of the scandal three years on and looks ahead to regulatory changes
The US president’s threats expose how one superpower can subjugate other countries using tariffs as an economic weapon
The US president has softened his stance on tariffs over Greenland; in other news, a partner from Osborne Clarke has won a High Court appeal against the Solicitors Regulation Authority
Emmanuel Manda tells ITR about early morning boxing, working on Zambia’s only refinery, and what makes tax cool
Gift this article