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

The future chief tax officer will be judged not only on compliance, but on their ability to harness data, technology and AI to support strategic decision-making
More than 200 tier promotions reshaped this year's European rankings as several international firms strengthened their positions in key tax markets
Ryosuke Takemura, OECD policy adviser, countered that the organisation’s role is ‘not to solve these issues one by one’ but to prevent tax disputes in general
Awards
ITR is delighted to reveal all the shortlisted nominees for the 2026 Asia-Pacific Tax Awards
Monica Erasmus-Koen and her Taxtimbre team will be responsible for building the firm’s TP capability in the competitive Netherlands market
Howden’s Rian Bahia explains how tax insurance can address known risks, unlock transactions and offer an alternative route through disputes and uncertainty
Haynes Boone’s new London partner, Alexandra Ueno-Park, argues that one-size-fits-all policies, billable-hour targets and outdated networking expectations can hold talent back
Death, taxes and Deloitte hoovering up trophies at an ITR awards night. Isn’t that the saying?
AI, pillar two and joint audits could define the next era of tax controversy, says Baker McKenzie tax partner Ariane Calloud
Gregor McMillan of Howden explains how insurance-backed financing can help businesses and funds unlock liquidity from tax receivables and other contingent claims
Gift this article