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MEMBER 263 writes:

"Thanks to The Tax Institute for eliciting the ATO response - see 2013 TAXVINE No 44 (15 November 2013) - to the feedback from Members 243 and 244 about stopping paper Activity Statements (AS) - see 2013 TAXVINE No 43 (8 November 2013).

Some accounting firms, like first and second tier firms, took a position from the outset to have all AS sent to them and then 'drive' their AS services. These planned ATO arrangements of no paper AS clearly will assist those practices. Not having paper forms or not having emailed forms will clearly help them.

There are however a lot of practices (especially sole and two partner firms) that took a different route with AS, that was all AS went to their clients (the tax agent (TAG) receives none). The client has then primary responsibility to choose how they do their AS. Of course, the TAG will assist in any way the client arranges. In this case the arrangements can be quite routine, the TAG does the BAS all the time, or varying with the TAG doing it for specific times (capital acquisitions, varying instalments, using TAG lodgment concession). 

A common example is a client who does their own BAS, paper lodge, then on one occasion (for one of the above reasons) the TAG lodges the BAS by ELS or otherwise electronic, so it would then seem all future BAS revert to non-paper, when the client would want to go back to doing their BAS via paper.

Another big issue for us is the paper BAS provides the initiative for the client to get their information to the TAG if the TAG is preparing the form. Without the paper AS the onus is going to be on TAGs to drive lodgments, that is what will happen in real life.

I suggest that for any practice that has the arrangement of paper AS going direct to clients, this change will put extra workload and hassle on TAGs (and no, in the real world, it is not billable time to small clients, and why should clients pay for the ATO savings?).

And I note the change is going to be implemented towards the middle of 2014, thus probably for the June BAS. So, at a time when small practitioners are the busiest, July/August, the ATO is inconsiderately planning to implement an arrangement that will, in all likelihood, be a significant resource waster.

Perhaps the ATO might respond to whether their 'pilot' covered these issues, and the many more, and whether they have solutions?

It is requested other TAGs consider how this is going to work for them, as this has the potential to being a big issue in six months' time."