Appropriate tax accounting arrangements enable the company's relevant liabilities to be calculated accurately in all material respects.

Where a company is a member of a group, the concept of ‘accurately in all material respects’ must be considered in relation to the company, not the group.

The Senior Accounting Officer (SAO) provisions do not impose a higher standard of accuracy than already exist for preparing returns. Neither do they bring accountancy or audit ‘materiality’ into the legislation.

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