Issued: 4 August 2025
Last modified: 22 August 2025
Join our executive team for an open session where you ask us the questions in relation to your obligations as a registered tax practitioner. We’ll answer questions about registration, compliance, policy, legislative reform and IT.
Resources
Webinar recording
Questions and answers
We have compiled some of the questions we received during our webinar.
Proof of identity
See FAQs - Proof of identity for client verification
Whistleblowing
What’s my obligations to disengage (or continue to engage) with a client who I know is unable to pay their tax debts?
It is a matter for you to determine which clients you do and do not engage with. There is no prohibition under our legislation in relation to dealing with clients who are unable to pay their tax debts. In these circumstances, you may be able to offer support or solutions to your client, having regard to relevant Australian Taxation Offices policies and procedures.
What action should I take to stop unregistered preparers targeting migrant workers to provide tax services?
If you are aware of an unregistered entity advertising or providing tax agent or BAS services, you can make a complaint to us via our online form.
Registration
Can I let my registration lapse rather than have a succession plan?
Yes, you can choose to let your registration lapse. We recommend you advise your clients so they can make alternative arrangements for their future taxation affairs. You should also ensure that your clients’ tax affairs are finalised before your registration lapses.
For further information see Ending your registration.
What should be done if a registered tax practitioner dies?
If a registered tax practitioner dies, their registration with us must be terminated. The executor of the estate, next of kin or other representative should notify us as soon as possible. Refer to Death of tax practitioner for further information.
Does completing volunteer work for a Tax Help program of the ATO count as relevant experience when applying for a tax agent registration?
We may accept work other than work under the supervision of a registered tax agent or as a legal practitioner, provided your experience includes substantial involvement in:
- one or more types of tax agent services
- a particular area of taxation law.
We will assess if an individual has met the relevant experience requirement on a case-by-case basis.
Are tax agents required to provide a certificate of currency of their professional indemnity (PI) insurance to the TPB after renewal each year?
You must update your PI insurance details with us every time you renew or change your insurance via My Profile on our website. It is not necessary for you to upload or provide your Certificate of currency to us, unless we request this from you.
If I’m registered as a sole trader, can I use that registration to operate under a company, or am I required to register as a company also?
To provide tax agent or BAS services through a company structure, you will need to register the company. You will also need to maintain your individual registration as the company requires registered individuals to provide services on its behalf and for supervisory purposes.
If I have gained my registration via membership with a professional body, do I need to maintain this membership or can I cease to be a member and still maintain my registration?
If you relied on a voting membership with a recognised professional association to obtain your registration, it is important for you to keep this membership to maintain your registration, unless you will qualify for a registration under one of the other registration pathways. Before you cease your voting membership, contact us to check if you may qualify for a continued registration through another registration pathway.
If I have been diagnosed with a mental illness can I still continue to act as a tax practitioner?
If your mental health impacts on your ability to provide services or run your practice effectively, please contact us. We also strongly encourage you to seek professional help as early as possible. For further information, refer to Seeking mental health support.
Is it mandatory to be a member of a professional association body to be registered with the TPB?
No, it is not mandatory to be a member of a professional association to obtain TPB registration. In some cases, being a voting member of a recognised professional association can assist with obtaining and maintaining your TPB registration.
In addition to having PI cover, does the TPB require tax practitioners to have cyber insurance?
Cyber insurance cover is not a requirement under the Code of Professional Conduct. However, we recommend you consider additional features to your professional indemnity insurance policy, including fraud and protection against cyber threats, including losses that an agent may suffer from a cyber-attack.
As registered tax practitioners, you hold large amounts of confidential information about your clients which may be accessible electronically. Data is an increasingly valuable resource that is likely to be targeted or inadvertently disclosed through security breaches.
In addition, most practices are reliant on the ongoing availability of computer systems and networks for their day-to-day activities. This means that the consequences of a cyber-attack resulting in computer systems being damaged or taken offline could be severe.
Continuing professional education (CPE)
Does reading newsletters from the ATO/TPB count towards my CPE?
Yes they can count towards your CPE but remember no more than 25% of CPE over 3 years should be undertaken through relevant technical or professional reading.
Quality management system
Is a quality management system compulsory?
Yes, all registered tax practitioners must establish and maintain a quality management system (QMS) to ensure that it provides them with reasonable confidence that they are complying with the Tax Agent Services Act 2009, including the Code of Professional Conduct (Code) and the Code Determination.
However, the extent and types of internal controls required will depend on the size and complexity of the individual practices.
Refer to our guidance on what elements a QMS should include.
Does the TPB have a template for QMS?
We do not have a template for QMS. You may seek assistance from your professional association.
Cloud computing, outsourcing and offshoring
What factors should a tax practitioner consider when they choose to provide their services while located outside Australia and their systems are entirely cloud-based?
When using cloud arrangements, tax practitioners should be mindful of their Code obligations, particularly Code item 6. Code item 6 requires tax practitioners not to disclose any information relating to a client’s affairs to a third party without the client’s permission, unless there is a legal duty to do so.
Tax practitioners should also refer to our guidance, which provides information about various factors tax practitioners will need to consider when entering into cloud arrangements.
What are some of the important considerations that we as tax professionals need to be aware of when entering into outsourcing or offshoring arrangements?
When entering into outsourcing and offshoring arrangements, tax practitioners should consider various factors depending on their circumstances and the nature of the arrangements they have with the third-party service provider. Our guidance provides further information for tax practitioners about what they should consider.
There are also several Code obligations that would be relevant when using outsourcing or offshoring arrangements. Tax practitioners must ensure they comply with their Code obligations when entering into outsourcing/offshoring arrangements, including making appropriate disclosure to clients and obtaining their clients’ permission before disclosing their information to a third party.
For further information see our guidance.