Issued: 23 November 2022
Last modified: 29 November 2022
View the resources for our webinar, Are you ready to renew? This webinar will help you understand your requirements for renewal. We’ll take you through the process of how you renew, as well as the important things you need to do to maintain your tax or BAS agent registration.
Questions and answers
We have compiled some of the questions we received during the webinar.
Who needs to register?
Does a bookkeeper as an employee who prepares her employer's BAS need to be registered as a BAS agent?
An employee or contractor of a registered tax or BAS agent who does not provide BAS services in their own right does not need to register with us. If you intend to advertise your services and charge a fee to provide BAS agent services then you must register with the TPB.
Also, if you are working for a registered company or partnership tax or BAS agent, the company or partnership might need you (as an individual) to be registered so that it has a sufficient number of registered individual BAS agents.
If I provide bookkeeping services in Australia, do I need to be registered as a BAS agent?
You need to register as a BAS agent if you provide BAS services for a fee or other reward. BAS services relate to:
working out or advising about liabilities, obligations or entitlements of clients under a BAS provision, or
representing a client in their dealings with the Commissioner of Taxation in relation to a BAS provision
where it is reasonable to expect a client to rely on the service to satisfy liabilities or obligations, or to claim entitlements, under a BAS provision.
I’m currently a sole trader, but I want to become a partnership. How can I change my status from sole trader to partnership on My Profile?
If you wish to change from a sole trader to a partnership you will need to lodge a new partnership application. Remember that all partnerships and companies must have a sufficient number of individuals registered to provide adequate supervision and control. If this is going to be you, then you will need to maintain your individual registration as well as applying to register as a partnership tax practitioner. Find out more about our registration options.
Can I register for a shorter period than 3 years? For example, if my retirement is coming up.
No, the registration period set out in the Tax Agent Services Act 2009 is at least 3 years.
If I’m a sole trader tax agent and become a company and am the sole director. Do I need both a company tax agent registration as well as my individual registration?
Yes, a company registration must have a sufficient number of registered individual tax agents to provide tax services to a competent standard and to carry out supervisory arrangements. Therefore, you would need at least one individual tax agent registered. You will also need to assess your sufficient number. This can be based on a number of factors – learn more about what you should consider when deciding your sufficient number.
Do we have to pay 2 registration fees if we are registered as an individual and are operating through a company?
Yes, each registered entity must pay an application fee to register and renew their registration.
Where on the My Profile page can I find my renewal date?
Will the TPB send me a reminder when my registration is coming up for renewal?
If I terminate my recognised professional association membership, will I still be able to renew?
If you terminate your membership of a recognised professional association, it may affect your registration, if you are relying on that membership for your ongoing registration requirements and to renew -under items 102, 206 or 210.
Do I need to provide client references to renew my registration?
No, client references are not a renewal requirement.
I meet all the requirements to renew, except I do not have the required hours of relevant experience. I am semi-retired, so am not working a lot. Is it possible to get an exemption?
Unfortunately, we are unable to give an exemption to the relevant experience requirements. These are a legislative requirement to maintain your registration.
Can our registration be updated with any conditions or registration requirements so we can plan ahead before renewal?
Why does the TPB need a copy of the receipt when we have paid our application fee?
Payments are made on the Governments Ezypay or BPAY websites and must be made before we can process an application. By providing a copy of your receipt at the time of your application this assists us to locate and match your payment to your new or renewal application.
Update your details
I’ve just been married – how do I change my identity documents with the TPB and update my registration details?
My username to login to My Profile is an old email address. Can I change the username to another email?
You will need to contact us and provide your username, email address registered with us, new email address and your phone number. We will then advise you when we have updated your details or contact you if we need further information.
How can I change my business name for my registration?
Proof of identity
When completing proof of identity, do the actual identity documents need to be loaded on the TPB website, or is it just the number of your driver licence, etc sufficient?
You do not need to load your identity documents you are only required to submit the identity documents numbers. This is done via the Document Verification Service (DVS), a national online system that allows authorised agencies to verify certain identity documents issued by a range of Australian, State or Territory government agencies. See more on proof of identity (POI).
Can POI be done via myGovID?
No, not at the moment. We are looking at this as a future enhancement.
How do I know if I have already completed the one-off POI process?
If you haven’t already completed the POI process you will automatically be prompted to complete it at your next renewal.
Can we complete the POI process now rather than wait for renewal?
If you have yet to complete the POI process, you will need to complete this process at your next renewal.
How we can setup multi-factor authentication?
How do we update the email address used for account verification?
Maintaining your registration
Do I need to notify the TPB if I’m taking a period of time out from my business, for example 6-12 months?
No, you do not need to notify us of this. But make sure you keep in mind that you have to meet the relevant experience requirement when you go to renew your registration. Keep in mind, that if you are the sole supervising tax practitioner responsible for supervision and control of a company or partnership you must ensure that another supervising tax practitioner is linked to the entity before you take leave. Learn more about relevant experience for tax agents and BAS agents.
I was previously operating as an individual tax agent and now I’m operating as a tax company. Do I need to notify TPB?
Yes, you must notify us within 30 days on which you become, or ought to have become, aware of any changes to your practice structure. Importantly, to advertise and provide tax practitioner services through the company for a fee or other reward, it must be registered with us.
Learn more about changes in circumstances.
Does a tax agent have to lodge a minimum number of tax returns to remain registered?
No, there is not a minimum requirement of lodgements to remain registered, but you must have enough relevant experience when you come to renew your registration with us.
I no longer provide services or charge a fee as a sole trader, but I want to maintain my registration. Do I still need to have professional indemnity insurance in place?
To maintain your registration, you need to maintain relevant experience, be a fit and proper person, complete continuing professional education (CPE) and maintain professional indemnity (PI) insurance. If you do not charge a fee or reward you can advise us of this on your renewal application. Find out more about PI Insurance.
Continuing professional education
I’m studying a diploma of business, does this count towards my CPE?
As long as this study isn't being used as a primary qualification for registration purposes, then you can claim it as CPE.
I’m transitioning to retirement and only work 2 days a month for a maximum of 12 hours a month. Do I still need to have the 90 hours of CPE over the 3-year period for a BAS agent?
Yes, you still need to maintain your CPE requirements during your registration period.
Does a CPR course count toward the CPE health and wellbeing allowance?
A CPR course does not meet our health and wellbeing allowance because the allowance only covers educational activities relating to managing stress, self-care and supporting mental health and wellbeing of your staff.
If a small business has been registered with the TPB and they use a contractor who is also registered with the TPB, does the director of the small business also need to complete CPE?
If the director is a registered tax or BAS agent they would need to complete CPE that meets our requirements.
How do we find out how many CPE hours we have completed?
You need to keep a record of your CPE activities and the hours you have completed. We recommend you complete this as soon as possible and practicable after you complete the activity.
You should include sufficient details about the activities and the hours completed. Where the CPE activity is unstructured, (for example, technical or professional reading, video or audio materials or group discussions on technical topics), you should record sufficient details to show the relevance of the activity to the tax agent or BAS services you provide.
For structured activities, evidence can include email confirmation for training, webinars or courses attended. You can use our CPE log or that of your professional association to record details. You must keep your CPE records for five years from the end of the relevant CPE period.
Are our CPE records from our recognised professional associations shared with the TPB?
No, we do not receive records of your CPE from recognised professional associations.
If I’m a research and development tax agent how much CPE do I need to complete?
You need to complete 45 hours of CPE over a standard 3-year registration period, with a minimum of 5 hours each year.
Does the CPE I complete for my recognised professional association, such as IPA and CPA, count towards my TPB CPE as a tax agent or BAS agent?
Generally, the CPE you complete for your recognised professional association will count towards your TPB CPE hours. As long as it related to the tax or BAS agent services you provide. Find out more about CPE activities.
Professional indemnity insurance
I’m an individually registered tax agent, however I work full-time as an employee. With PI insurance, can I provide my employer's PI insurance details, or do I need my own insurance?
If you charge a fee or other reward for providing tax agent services PI insurance is a legislative requirement. If you are an employee of a registered tax practitioner you can rely on your employers PI insurance.
Does a company and an individual tax agent need to have PI insurance?
Company tax and BAS agents will require PI insurance that meets our requirements. For individuals – if you do not provide services for a fee or other reward in your own right, for example you are an employee, you may not need your own policy and can advise us of the details of your employer (if they are registered with us). Find out more about PI insurance.
Do I need to update my PI insurance details in My Profile?
Can I update my PI insurance details in My Profile before my current policy expires or do I need to wait?
You can update your PI insurance details in My Profile at any time. Make sure you include the future start and end date of your new policy.
Fit and proper requirements
Would you be considered not to be a fit and proper person if you have not lodged your own individual tax return?
In deciding if an individual is a fit and proper person, we must consider a number of factors. However, conduct that leads to a breach for not complying with your personal taxation obligations (Code item 2) could impact on a tax practitioner meeting the fit and proper person requirement.
Importantly, if a registered tax agent or BAS agent ceases to meet the fit and proper person requirement, we may decide to terminate their registration.
Personal tax obligations
Can we have a payment plan in place with the Australian Taxation Office for outstanding tax debts and still be able to renew our registration?
A registered tax practitioner will have complied with the taxation laws in the conduct of their personal affairs if they have paid their tax debts by the due date or have entered into, and are complying with a formal payment arrangement with the Australian Taxation Office (ATO) to pay their tax debt by instalments. You also need to declare this arrangement with us when you renew.
Do personal tax obligations include a Higher Education Contribution Scheme debt?
A Higher Education Contribution Scheme (HECS) debt is not a 'taxation law' administered by the Commissioner of Taxation, but rather a Commonwealth loan administered under the Higher Education Support Act 2003. A HECS debt would be reflected in your tax return and if there is a tax debt resulting from this return, then the tax debt would need to be disclosed to the TPB at renewal.
If you don’t have a tax debt and just have a HECS loan, then this would not need to be disclosed because it's not a tax debt.
If I volunteer with ATO’s tax help program will this count towards relevant experience as a tax agent?
For your experience to count if must be:
as a registered tax agent
under the supervision and control of a registered tax agent
as a legal practitioner
of another kind.
It must include substantial involvement in one or more types of tax agent services, or substantial involvement in an area of taxation law to which one or more of those types of tax agent services relate.
Given the recent problems experienced with hackers by other large organisations, what comfort do tax practitioners have that the TPB has secured the proof of identity information supplied at the time of renewal from hackers?
Our systems do not store proof of identify documents or associated information. During the process we send and verify the identity details tax practitioners provide securely with the Whole of Government Document Verification Service. Once the transaction to confirm your identify is completed, our systems only have a record of the outcome of the check, but none of the intermediate documents or details. See more on IDMatch’s website.