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Chapter SAOG14515

Document Cited in Related
Vincent
Published date19 March 2016
Record NumberSAOG14515

The examples in SAOG14510 - 14515 illustrate some situations where reasonable steps are taken. The examples illustrate the point but are not exhaustive.

Example 6 - Takeover or merger

A qualifying company is purchased by new owners shortly after the beginning of its financial year. A new person is identified as its Senior Accounting Officer (SAO) at that point. HMRC makes an enquiry into the company’s return for the financial year in which the take over took place and finds errors in its PAYE systems.

The Customer Compliance Manager (CCM) or Mid-sized Business Caseworker obtains documentation that shows that shortcomings were drawn to the attention of the new SAO at an early point after the takeover. However, the SAO cannot show that they took or commenced any action to put this right. They have not taken...

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