Senior Accounting Officer (SAO) and #coronavirus Job Retention Scheme (CJRS)

Senior Accounting Officer

The Senior Accounting Officer (SAO) regime was introduced by the UK Government in 2009, to ensure that large companies (broadly, those with a relevant balance sheet total exceeding £2bn and/or a turnover exceeding £200M) take reasonable steps to ensure that “appropriate tax accounting arrangements” are in place.

A Senior Accounting Officer (SAO) is the director or officer of a company who, in the company’s reasonable opinion, has overall responsibility for the company’s financial accounting arrangements.

With many job roles in the UK being furloughed and grants being provided by UK government to support business and keep Britain paid, many calculations of grant claim are being handled by the payroll profession. Business are taking strategic decisions to manage funds and to survive #COVID19. Desperate situations can lead to rushed decisions. The UK government priority is to save jobs yet are aware that some potential criminal fraudulent activity may also be attempted.

What about the #coronavirus Job Retention Scheme?

HMRC confirm that they ‘consider the CJRS grants do come within the SAO regime. The grants will be part of a company’s receipts for CT [Corporation Tax] purposes and the employee wages and NICs will be a business expense in calculating taxable profit, so fall within paragraph 14(3)(a) schedule 46. Therefore, a company’s SAO will need to ensure appropriate accounting arrangements for CJRS grants and the wages they cover’.

Where there is an SAO in place, are they aware and overseeing the grant application process to ensure that SAO responsibilities are being maintained?

If your business falls under SAO requirements, have they ensured that the processes for the Coronavirus Job Retention Scheme have ‘appropriate tax accounting arrangements’ and that the calculations are ‘accurate in all respects’?

Senior Accounting Officer

PAYadvice.UK 14/5/2020

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