Effective for 2009, HM Revenue & Customs (HMRC) has introduced Schedule 46 of Finance Act 2009 (Schedule 46). The objective of this new legislation is to ensure that senior accounting officers (SAO) of large companies liable to taxes and duties in the United Kingdom are responsible for ensuring and certifying that appropriate tax accounting arrangements have been established and maintained.

To understand what constitutes reasonable steps, it is helpful to review the requirements of Schedule 46 and learn from the guidance provided to senior accounting officers (SAOs) of large companies. In this booklet, we answer common questions regarding Schedule 46 and suggest a roadmap to compliance.