Issued: 20 March 2025
Last modified: 8 May 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.
Registration
How many tax returns do I need to lodge to remain registered?
It is not necessarily about the number of returns completed. Tax practitioners must continue to meet the registration requirements for the Regulation they are registered under. For example: the relevant experience requirement for Regulation 201 is 12 months full time equivalent in the preceding 5 years.
You do not have to complete a statement of relevant experience to demonstrate your relevant experience when renewing your registration. However, in the online renewal form you must confirm you meet the required relevant experience to renew your registration.
I have a registration that expires in 2026 will I still receive an email reminder from the TPB to renew, or do I need to monitor this ourselves?
Yes, you will receive reminders from us when your renewal is due. That is why it is important to keep your details up to date with us. We send reminders to you via email then SMS. It is always a good idea to make a note of your renewal expiry date (or add a reminder in your outlook calendar) and lodge your renewal application as soon as it is available via My Profile.
Do I have to be a registered BAS agent if I enter BAS invoices into an accounting platform, but don’t lodge the BAS (the accountant does this)?
Not necessarily. This will depend on whether the service amounts to a tax agent service (which includes a BAS service), and if it is provided for a fee or other reward. You can visit our website for a comprehensive list of BAS Services.
Can I do work for a non-qualified tax company as a BAS agent?
If you are providing inhouse BAS services to the company, as an employee, then yes. However, the company must be registered as a tax or BAS agent to provide tax practitioner services for a fee or other reward and to invoice and advertise those services.
Do registered tax agents automatically get registered BAS agent status, or do they need to apply separately for it?
Your registration appears on the TPB Register as a tax agent however, a registered tax agent can provide BAS agent services for a fee or other reward.
Is it possible to put your registration on hold temporarily or do you need to surrender your registration?
No, you cannot put your registration on hold. You can surrender and re-apply in the future if you need to be registered again.
Can I apply for an extension to renew my registration?
No, you must renew your registration before the registration expiry date.
If my company is a trustee which entity will need to be registered – the company, trust or individual?
The TPB registers the trustee (we do not register trusts) so if the trustee is a company we register the company, if the trustee is an individual we would register the individual. The registration includes details of the trust deeds and TFN/ABN for both entities.
If I have another year to go on annual renewal, do I need to do the annual declaration this year?
Tax practitioners do not need to complete an annual declaration starting from 1 July 2024, as this process has been replaced with an annual registration process.
TPB Register
Can we change our personal details such as email address and trading name on the TPB Register?
Yes, you can update your personal details either via your My Profile or by submitting a contact us form. To include a business name on your registration it must be registered with ASIC and if you are adding or changing your business name then you must submit a contact us form and provide evidence of the name change.
Can we remove our home office address from the TPB Register?
Your business address is published on the TPB Register. If you have a reason for not wanting to have your business address published on our register you will need to apply for a suppression of address by submitting a contact us form and providing reasons for your request.
Can supervised tax and BAS agents now be listed on the TPB Register?
Yes, we are required to publish details of supervising tax practitioners for partnerships and companies. This requirement applies to applications for registration (including renewals) made by a partnership or company from 5 July 2024.
Outsourcing and offshoring
If a business engages an offshore bookkeeper as a contractor, can the bookkeeper lodge BAS and undertake BAS services?
Yes, however the bookkeeper may need to be registered as a BAS agent or tax agent depending on whether they are an employee of the business or a contractor. For further information, refer to TPB(I) 13/2012 Contractors.
What are the rules around outsourcing in terms of the Code of Professional Conduct?
Registered tax practitioners may outsource certain services. However, they should be aware of their obligations under the Code of Professional Conduct (Code), including in relation to confidentiality and competence. For further information refer to our outsourcing and offshoring Practice note.
Supervision and control
How can I record supervisory arrangements in My Profile?
You may add and remove supervising tax practitioners via My Profile. Alternatively, you may also update this information at renewal. It is important to note that you must advise us of changes in your registration circumstances within 30 days.
Can I provide tax services and run a tax agent business by myself without hiring other employees?
Yes as long as your entity has an adequate number of registered individual tax or BAS agents to:
- provide tax agent or BAS services to a competent standard, and
- carry out supervisory arrangements on behalf of the entity.
For more information read our information on supervision, competency and quality management.
Is a trainee employee under the supervision of a registered BAS agent allowed to directly invoice a client for BAS services?
Yes, the trainee may invoice a client on behalf of the registered BAS agent.
Proof of identity (POI)
What Proof of Identity (POI) documents should I obtain for a new company/trust/partnership client?
For non-individual clients you will need to obtain a:
- document or data that verifies the existence of the non-individual client, and
- legal document showing the authority of the individual representative to engage you on the client’s behalf.
Examples of identification documents can be found on our Client verification process for tax practitioners page.
My firm provides GST advice to other registered tax practitioners. We do not engage directly with the client. What are our POI requirements?
If you are providing GST advice to another registered tax practitioner who has engaged you on behalf of a client, you will meet the our requirements if you receive written confirmation from the tax practitioner that they (or their firm) have undertaken proof of identity checks and confirmed the identity of the client.
How do I verify a client’s identity if I they have don’t have POI documents?
Some clients, such as some Aboriginal or Torres Strait Islanders, those who came as refugees or those affected by a natural disaster, may not be able to provide conventional forms of ID. In these situations, you should take a flexible approach. We recognise the POI steps you undertake in these situations may be different to or less than our minimum requirements. You should maintain detailed records to outline the client’s situation and the steps you have taken to establish their identity. For more information read our Proof of identity requirements for client verification practice note.
Do we keep the POI documents on file? If not, how do we prove that we received POI documents?
We do not recommend that you to keep copies or originals of IDs you used to identify a client or their representative. However, you should maintain a record, such as a checklist, with sufficient details as soon as POI checks are undertaken. For example, records should contain date and time when POI checks were done, types of IDs used, how the documents were sighted and who in the practice performed the checks including their position. The records must also include confirmation that the IDs were clear and legible, identified the client and their representative (if any) and there was no apparent reason to question the IDs provided. The records must be kept for up to at least 5 years after the engagement with your client and/or their representative ceases.
Professional indemnity (PI) insurance
What PI insurance details do you provide when you are covered by your employer?
When entering your detail in My Profile, you must select the correct option to advise that you are covered by the PI insurance of another entity and include the Registration number of the registered agent.
How long do you have to report your PI to the TPB after the due date?
You should maintain current PI insurance details at all times throughout your registration, and you must advise of your new policy details as soon as it is renewed. To update your PI insurance details simply go to My profile and select the appropriate option to update this information.
Continuing professional education (CPE)
With minimum number of CPE hours within a 3-year registration, what happens if 120 hours is completed in the first year, do I still need to do CPE hours in the following 2 years?
The standard minimum number of CPE hours for a registered tax agent is 120 hours within a 3-year period. However, there is a minimum requirement to complete 20 hours of CPE each year.
Is there a requirement to keep a certificate of attendance or is log sufficient for recording CPE?
You should maintain a record and evidence of the CPE activities you have completed. The record should be made as soon as possible after your CPE activity is completed and should include details of the activities and the hours completed. We have developed a CPE log that you may like to use to assist with your record keeping requirements. Please visit CPE webpage for further information.
As a sole trader does a first Aid course qualify as CPE?
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.
If a colleague and I are watching a webinar, can we both qualify to claim the CPE or is it the person who purchased the webinar?
Yes, you can both claim CPE for watching a webinar together as long as the webinar is relevant to the tax practitioner services that you provide and maintains, develops or promotes your skills, knowledge or attributes.
Cyber
How do know I where my data is stored on the cloud and how does it relate to confidentiality of client information?
Cloud computing, at a broad level, is the provision of information technology resources as a service through a network (including storing, managing and processing data), typically over the internet, instead of using a local server or a personal computer. When entering any arrangements with your provider make sure to ascertain where and how your information will be stored and managed.
When entering into cloud arrangements, you should also be mindful of your obligations under the Code. It is important to be mindful of Code item 6 which states a tax practitioner must not 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.
In addition to your obligations under the Code, you should also be aware that the Privacy Act 1988 (Cth) sets out a number of Australian Privacy Principles which govern the use of, storage and disclosure of personal information.
How can we avoid fraud through identity crime and ensure the true identity of the person we are speaking to before disclosing any information?
If you are contacted by someone and you’re not sure whether you’re dealing with a scammer you can:
- contact the person or organisation directly using contact details you’ve found yourself on the organisation’s official website
- access the organisations’ secure, authenticated portal or app (never via a link)
- watch out for slight variations in Caller or Sender IDs and website addresses like dots, special characters or numbers
- do online research of people and organisations who you’ve only dealt with online before paying any money – you can search the name online together with the word ‘scam’ to see if anything comes up.
How can cyber security threats affect my practice?
Cyber threats typically arise when your data, computer system, network, or device is targeted by a cyber attacker who seeks to gain unauthorised access or exploit any vulnerabilities present in your information management system, compromising its confidentiality, integrity, or availability.
A cyber-attack can have negative consequences for your business's operations, functions, brand or reputation. An attack may also affect your client’s data integrity, and value, as well as the people, processes, and technologies involved in managing that data.