Issued: 13 November 2023

Last modified: 29 November 2023

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View the resources for our webinar, Know your obligations. 

It’s important for new tax practitioners to understand their ongoing registration obligations. In this webinar we’ll provide everything you need to know to meet and maintain the high standards of the tax profession.


Webinar recording

Know your obligations webinar recording

Questions and answers

We have compiled some of the questions we received during our webinar.

Continuing professional education

You need to provide your continuing professional education (CPE) log or details of activities completed when we request you to do so. This may happen anytime during your registration period, including at the time you renew your registration.


We have a 25% reading cap on technical or professional reading.


Our CPE policy requires that no more than 25% of CPE should be undertaken through relevant technical or professional reading. However, due to the COVID situation we had a temporary concession in place that removed this 25% cap up until 1 January 2023. If you claim the research and reading you must also ensure that it was relevant to the tax agent or BAS services you provided.


Yes, just make sure you record the relevant information in your CPE log. Find out more about recording your CPE and download our CPE log


You don't need a certificate, but there are certain details you need to record. For example, keep a record of the date, the CPE provider, details of the activity including the format, the outcome or learning, hours completed and any evidence of attendance.


Our webinars generally run for one hour, so you can claim one hour of CPE for the purposes of the TPB. To claim CPE for meeting your recognised professional association’s requirements, it is best to ask for their advise as they may have a different system in place.


If you maintain a CPE log for your recognised professional association, that should generally meet our requirements too. You do not have to maintain a separate record for TPB purposes.


All registered individual tax and BAS agents must complete CPE to maintain their registration with us.


You can use this as long as it is relevant to the tax agent or BAS services you provide.


In this situation where you are unable to complete the minimum hours of CPE due to extenuation circumstances, you should exercise your professional judgment and keep appropriate records in relation to your situation. We will consider appropriate relief from the minimum amount of CPE hours, provided you can demonstrate that you have attempted to use the flexibility of your CPE period to manage any extenuating circumstances to comply with our CPE requirements.


No, these activities are not considered relevant as they do not relate to your services as a tax practitioner and are not considered mental health and wellbeing activities.


No, you can only claim relevant CPE activities from the time you are registered with us. Anything you complete before registration cannot be counted.


Your CPE period will begin on the date you are registered and end on the date your registration expires (generally 3 years). However, if you are a member of a recognised professional association, you can elect to align your CPE period with the CPE period of your professional association. This means that you can elect to have your CPE period based on a calendar year, financial year or the anniversary of your association membership start date. Find out more about your CPE period.


You can count the training you complete for your tax agent registration towards you BAS registration, if it is relevant to the services you are providing as a BAS agent.

Another thing to keep in mind, is that you don’t need to maintain both a tax and BAS agent registration. If you are a tax agent, you can complete BAS agent services under your registration.


You can complete activities offered by other organisations. Just ensure the CPE activities are relevant to the tax agent or BAS services you provide and are being provided by persons or organisations with suitable qualifications and/or practical experience in the subject area.


Your CPE activities can include up to 10% of educative health and wellbeing activities over your CPE period. These activities could include attending webinars about how to manage stress and self-care.

We recognise cyber security awareness training that you undertake as relevant CPE. We suggest you use your professional judgement on the amount of hours that would be appropriate to remain relevant to your registration as a tax or BAS agent.

Personal tax obligations

There is no issue with a tax agent lodging tax returns for their own personal tax affairs, including the tax affairs of their company, trust or self-managed super fund (SMSF), provided that your personal interests (including the interests of your company, trust or SMSF) do not conflict with your duty to act lawfully in the best interests of your clients. Where an actual or perceived conflict of interest exists, you should disclose the conflict to your clients and take steps to manage that conflict of interest. Refer to our Information sheet for further information.


Yes, this is acceptable if you declare this to us in your registration renewal and meet the arrangements that are outlined by the ATO in the payment plan.

Engagement letters

We don't provide a template for engagement letters. If you are a member of a recognised professional association, they often have templates they share with their members.


If you are providing tax agent or BAS services as a contractor working for a tax or BAS agent, we recommend an engagement letter be used between the client and the tax practitioner providing the service. This engagement letter should include terms obtaining consent from the client for use of third-party contractors to provide the services, including any disclosures of client information to those contractors to provide services on behalf of the tax practitioner. Take a look at our Practice note to learn more about outsourcing services.


An employee or contractor of a registered tax or BAS agent who does not provide tax agent services in their own right, does not need to be registered. However, if they are working for a registered company or partnership tax agent, the company or partnership might need them (as an individual) to be registered so that it has a sufficient number of registered individual tax practitioners. Registered tax or BAS agents must also ensure that tax agent services provided on their behalf are provided competently, which means they must have adequate supervision and control over a trainee tax or BAS agent who isn’t registered with the TPB.


No, there is not a minimum requirement of lodgements to remain registered, but you must meet the relevant experience requirement for your registration pathway when you come to renew your registration with us.


If the bookkeeper is not providing BAS agent services for a fee or other reward, they do not need to register with us. 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.

Find out more about BAS services.


You can register as one company, but if you register as a company or partnership, you also need to have a sufficient number of registered individuals who carry out supervisory arrangements on behalf of the business. This means your entity must have an adequate number of registered individual tax practitioners to:

  • provide tax agent services to a competent standard, and 
  • carry out supervisory arrangements on behalf of the entity. 

There is no set formula for the number of individual registrations you will require. You will need to work this out based on a number of factors. Find out more about what to consider.


Anyone providing tax agent or BAS services for a fee or other reward must be registered as a tax practitioner before providing those services. If you provide tax agent or BAS services while unregistered, you may be liable for civil penalties. Find out more information on unregistered preparers.


We do not have any specific requirements relating to Public Practice Certificates. However, as a registered tax practitioner, you are required under the Code of Professional Conduct to ensure that tax agent or BAS services you provide are provided competently, and that you maintain knowledge and skills relevant to the tax agent services you provide.

Please refer to CPA Australia's requirements in relation to whether you are required to hold a Public Practice Certificate.


If you are a registered BAS agent and a voting member of a recognised professional association, you must consider whether you will continue to meet the qualification and experience requirements for maintaining registration as a BAS agent, if you cease to be a voting member of that association. See our guidance on the qualification and experience requirements for BAS agents, including those who are not voting members of a recognised professional association for more information.


If you register as a company or partnership, you also need to have a sufficient number of registered individuals who carry out supervisory arrangements on behalf of your business. For example, if you operate your business through a company, the company will need to be registered and you will either need to be registered as an individual as well, or the company will need to have other registered individuals who can carry out supervisory arrangements on its behalf.


The Tax Agent Services Act 2009 states that you must be registered with the TPB to provide BAS services for a fee or other reward. However, the meaning of 'fee or other reward' excludes employees (who are not registered with the TPB) who provide tax agent services or BAS services on behalf of (or to) their employer for a salary, wage or other benefit. You should consider whether your engagement with the not-for-profit organisation meets the criteria for this exclusion. For further information, please refer to our Information sheet.

Outsourcing and offshoring

If you are considering hiring remote staff overseas to provide tax agent or BAS services on your behalf, you should consider our 'outsourcing and offshoring' guidance. Offshoring occurs where an entity enters into an arrangement to transfer a process, function, service or activity outside Australia. Under the Code, you must ensure that the arrangement complies with Code item 6, which requires tax practitioners do not disclose any client information to a third party without the client's permission, unless there is a legal duty to do so. You must also consider Code item 7, which requires tax practitioners to ensure that services are provided competently, which includes adequate supervision of those providing services on their behalf. Refer to our Practice note for more.


Ultimately, a registered tax practitioner is responsible for the services they provide. However, the scope of responsibility can vary based on the type of outsourcing arrangement. For example, if you (as a registered tax practitioner) outsource the preparation and lodgement of a return to a third party (who is also a registered tax practitioner), you are not required to provide supervision or control over the third party’s work. However, if you will still be lodging the return, you are required to ensure this tax agent service (the lodging of the return) is provided competently. This includes taking reasonable care to ensure tax laws have been applied correctly, and to ascertain the client’s state of affairs, which may require you to review the return prepared by the third party. You are also required to consider if the outsourcing arrangement is appropriate for the circumstances, both before entering and during the course of the arrangement. For further information, refer to our Practice note.

Professional indemnity insurance

This is not a legal requirement under the Code of Professional Conduct, but we recommend you consider additional features to your professional indemnity (PI) insurance policy, including fraud and protection against cyber threats, including losses that you may suffer from a cyber-attack. Learn more about our PI insurance requirements.


We only have the power to formally investigate certain matters under Tax Agent Services Act 2009 (TASA). This includes:

  1. applications for registration
  2. breaches of the Code of Professional Conduct
  3. any false or misleading statements made to the Commissioner of Taxation
  4. advertising or supplying tax agent services when not registered
  5. any other conduct that may breach the TASA.

If we find a tax practitioner may have committed a criminal offence, we will refer this to the relevant law enforcement agency.


The government has announced a range of reforms to address tax adviser misconduct and improve regulatory frameworks with three priority areas to:

  • strengthen tax system integrity
  • increase powers, and 
  • ensure regulatory arrangements are fit for purpose. 

New legislation is expected to be introduced after broader consultation on the reforms. In the longer term, whole of Government reforms to improve regulatory frameworks will be coordinated by Treasury and delivered progressively. These reforms address improvements identified in the independent review of the TPB conducted by Mr Keith James and build on TASA reforms currently before Parliament.