Why CFOs can no longer ignore personal accountability for tax compliance 

Tighter global tax rules and increased enforcement mean personal exposure and accountability are rising for finance leaders in multinational businesses. CFOs are increasingly finding themselves personally accountable for tax compliance failures. 

This is not just about reputational damage, many tax regimes now impose financial and possibly criminal liability on individuals for failures in oversight, governance, and reporting. 

Whether your business is operating across 10+ countries, or just has a UK presence with global customers, personal accountability is now embedded in the legal and regulatory frameworks in the UK, US and EU. 

1. In the UK: the line between corporate and personal responsibility is narrowing

• Criminal Finances Act 2017: Companies can be held strictly criminally liable if employees or associated persons facilitate tax evasion, and senior management do face heightened scrutiny and potential consequences for failing to prevent it. 

• Senior Accounting Officer (SAO) regime: Often the CFO, the SAO must personally certify that the company’s tax accounting systems are adequate. Failure to do so can result in personal penalties of £5,000 per offence. 

• Director liability: Directors can be held personally liable for tax-related fraud, misuse of insolvency processes, and – under certain circumstances – even late payment of taxes if negligence or misconduct is proven. 

2. In the US: individual liability is an enforcement priority

• Payroll tax enforcement: The IRS routinely holds CFOs and other officers personally liable for unpaid payroll taxes, including interest and penalties. 

• Sarbanes-Oxley Act (SOX): CFOs and CEOs must certify the accuracy of financial statements, including tax provisions. Inaccurate certification can trigger civil or criminal sanctions. 

• State-level exposure: Many states impose personal liability on officers for unpaid taxes, such as sales and payroll taxes, even if the company itself is insolvent. 

3. In the EU: compliance requirements are expanding and increasingly digital

• Anti-Tax Avoidance Directive (ATAD): While not directly imposing personal liability, ATAD has raised the standard for cross-border governance. Some member states (e.g. France and Germany) do impose personal liability on directors for tax negligence. 

• Real-time VAT and e-invoicing systems: These regimes are being rolled out across multiple jurisdictions. Breaches may result in immediate financial penalties-sometimes with strict liability. 

• DAC6 and mandatory disclosure: CFOs must ensure cross-border tax arrangements are disclosed where required. Non-compliance can trigger penalties for both the entity and the individuals involved. 

What should CFOs do now? 

You can no longer delegate tax risk entirely to advisers or tax teams. Your own role, signature, and oversight may carry legal weight. 

Three practical steps: 

• Review the tax governance framework and internal controls across the group. 

• Map your personal obligations under SAO, SOX, DAC6, and relevant national rules. 

• Work with advisers and internal audit to identify areas of risk and strengthen oversight. 

Tax governance is no longer just about protecting the business. It’s also about protecting yourself. Personal liability is not theoretical; it’s already being tested in enforcement actions around the world. Finance leaders must act accordingly. 

Need support improving your tax governance and managing international compliance? Set up a customised review or in-depth look at your tax governance with Neeraj Nagarkatti or Angelo Chirulli..