Other guidance

Issued: 8 December 2022

Last modified: 8 December 2022

To become a registered tax practitioner, individual applicants must meet certain relevant experience requirements. This guidance is for individuals who are considering gaining relevant experience from a tax practice that operates under a franchise arrangement, to apply for registration with the Tax Practitioners Board (TPB).

Depending on the structure of the franchise arrangement, you may be a franchisee operating a franchise business or an employee of or contractor for the franchise business. The franchisor may be the supervising tax practitioner or a company or partnership.

Your relevant experience needs to be gained under the supervision of a registered tax practitioner (also referred to as a ‘supervising tax practitioner’). A supervising tax practitioner is an individual who has been nominated for that role and is responsible for exercising supervision and control over your work.

Before entering into a franchise agreement, you should consider the following important information:

You must ensure the supervising tax practitioner is registered with the TPB by searching the TPB Register.


For your experience to count as relevant experience it must include substantial involvement in one or more types of tax agent services (including BAS services), or substantial involvement in an area of taxation law (including BAS provisions) to which one or more of those types of tax agent services relate.

If you are relying on experience gained under the supervision and control of a registered tax practitioner, the tax practitioner must verify the information you have provided in the Statement of relevant experience (SRE) form and comment on your ability to provide tax agent services to a competent standard. For further information on demonstrating your relevant experience, refer to:

We will consider a range of factors when determining whether adequate supervision and control was exercised by a tax practitioner over your work to meet our relevant experience requirements. Some of these factors include whether your supervising tax practitioner:

  • inspected, advised and directed how you undertook tasks

  • ensured that you have an adequate level of education and understanding of the relevant taxation law to undertake the tasks that you are or were responsible for

  • provided you with initial and ongoing training

  • has or had documented procedures and processes in place so you could raise any issues with the supervising tax practitioner that are or were beyond your knowledge or experience

  • implemented quality assurance and control mechanisms and conducted audits of work undertaken by you

  • undertook spot checks of the source documents and questions asked by you to justify the taxation law advice you provided.

If we determine that a tax practitioner did not exercise adequate supervision and control over your work, then that work experience may not be considered in determining whether you meet the relevant experience requirement.


You must consider how the supervising tax practitioner will provide you with adequate supervision and control if they are providing supervision and control to one or more other individuals or entities.

There is a range of factors we will consider in determining whether adequate supervisory arrangements exist where a nominated supervisor is supervising one or more entities. In addition to the factors summarised above, we will also consider the following:

  • size of each entity being supervised – for example, turnover of the business, number of clients, and number of relevant staff

  • market segment of the client base of each entity being supervised

  • type and complexity of the tax agent services being provided

  • other professional duties or responsibilities of the nominated supervisor.


There is a range of factors we will consider in determining whether adequate supervisory arrangements exist in remote working arrangements. In addition to the factors summarised above, we will also consider whether the supervising tax practitioner:

  • has frequent contact with you and their methods of communication with you

  • is available to be contacted by staff

  • has provided access to training and research resources

  • manages workflow, particularly where the supervision and control is being exercised by an unrelated entity

  • reviews documents and provides feedback to staff

  • manages file and document sharing logistics

  • carries out audits or reviews remotely

  • has other administrative obstacles inherent in a remote supervisory arrangement.


A company or partnership must have a sufficient number of tax practitioners to carry out supervisory arrangements. There is no set number for how many registered individuals are required to carry out these supervisory arrangements. The number of supervising tax practitioners will depend on a range of factors.

We will consider a range of factors to determine whether the company or partnership has a sufficient number of registered individuals to carry out supervisory arrangements, including:

  • Do they have adequate financial, technological and human resources to provide tax agent services and supervision?

  • Is the registered individual competent and adequately trained to provide effective supervision and control?

  • Does the registered individual only supervise the tax agent services they are registered to provide?

  • What is the size and scale of services provided within your business? This may include considerations such as their business turnover, number of clients, nature and sophistication of their client base and the number of relevant staff.

  • How complex are the services being provided and supervised?

  • How many qualified and experienced staff do they have and how often do staff undertake training and development activities?

  • Do they have sufficient technical support, including network security protocols and digital monitoring and review processes?

  • What supervisory arrangements do they have in place, including quality assurance and control practices and escalation procedures?

  • What are their risk management processes, including delegated supervision processes?

  • Does the company or partnership have a condition imposed on its registration by the TPB?

For further information regarding supervisory arrangements under the Tax Agent Services Act 2009 (TASA) refer to TPB(I) 36/2021 Supervisory arrangements under the Tax Agent Services Act 2009.


To rely on experience gained under a franchise arrangement, you will need to ensure that your supervising tax practitioner is registered with the TPB and you have received adequate supervision and control from your supervising tax practitioner that meets the factors outlined above. When applying to the TPB, you should provide evidence of your relevant experience gained under a franchise arrangement, such as the following:

  • the supervisory relationship between you and the tax practitioner

  • how the supervision and control was provided by the supervising tax practitioner (this will ordinarily include direct evidence from the supervising tax practitioner and may also include additional evidence that details the supervision and control arrangement)

  • the requisite number of years/hours under the appropriate regulation (depending on the qualifications held by the applicant), for further information visit:

  • any quality assurance processes and ongoing training/support provided under the arrangement

  • the franchise agreement

  • copies of invoices to clients and evidence of payment for services rendered.

If you are working as a contractor in a franchise business and providing services under the supervision of a tax practitioner, you will need to consider whether you must be registered with the TPB. For examples of circumstances where a contractor does or does not need to register with the TPB, refer to TPB(I) 13/2012 Contractors.


Case study

An unregistered individual enters into a franchise arrangement as a franchisee to obtain relevant experience to eventually apply for tax agent registration with the TPB. The individual made an application to the TPB claiming they had received relevant experience under the supervision and control of a supervising tax practitioner who was the director of the franchisor company.

However, both the supervising tax practitioner and franchisor company had their registrations with the TPB terminated, in part, for failing to provide adequate supervision and control. The individual also did not provide evidence to the TPB which demonstrated how they were subject to the supervising tax practitioner’s supervision and control.

Consequently, the individual failed to meet the TPB’s work experience registration requirements and the TPB decided to reject the individual’s application for tax agent registration.

For further information, see the TPB’s media release.


Further information

Register with the TPB

Contact us

If you have any questions about franchise arrangements or need further information regarding a franchise business structure, please contact us.