The term ‘appropriate tax accounting arrangements’ is defined at FA 2009, Sch. 46, para. 14 as meaning: ‘accounting arrangements that enable the company's relevant liabilities to be calculated accurately in all material respects’.

Meaning of ‘accounting arrangements’

Rather unhelpfully, the statutory definition of ‘accounting arrangements’ is simply ‘arrangements for keeping accounting records’ (FA 2009, Sch. 46, para. 14(2)). This fails to convey the breadth of a term which HMRC believe to cover ‘the end to end process from the initial data input into accounting systems to arriving at the numbers which form the basis for completion of the tax return’ (SAOG 14310).

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