Tax administration Consultation Treasury

Implementation of the Government's response to the Review of the Tax Practitioners Board

Author: The Tax Institute

Published Date: 15 Dec 2022


Sorry, this is subscriber only content.

If you're not yet a subscriber, to gain access to this material and much more - Subscribe Now.

Already a Subscriber? Login now

Already a Subscriber? Login now

The external professional association members of the Tax Practitioners Board (TPB) Tax Practitioner Governance and Standards Forum (TPGSF), collectively the Joint Bodies, make this submission in response to consultation on the Exposure Draft Treasury Laws Amendment (Measures for Consultation) Bill 2022: Tax Practitioners Board Review (the ED). Additional professional association members from the TPB Consultative Forum also support the views presented in this submission.

We thank Treasury for the opportunity to discuss the consultation at the TPB Forum on 6 December. This submission provides further details of the Joint Bodies’ response to the changes proposed in the ED.

The complexity and scope of Australia’s tax and superannuation system means that almost all Australian businesses and almost two-thirds of individuals use a tax practitioner to help them with their tax affairs. As at 30 June 2022, there were 45,333 tax agents and 17,007 BAS agents. Many of these agents employ others. Collectively, they employ tens of thousands more people, to provide tax advice, as well as prepare and lodge the millions of returns and forms required by the ATO each year.

The size and importance of the tax profession means that changes to the regulatory framework need to be properly considered and carefully implemented. The Joint Bodies support the progression of the recommendations arising from the Review of the Tax Practitioners Board (the Review) in 2019. and acknowledge the refinement of proposals since the publication of the Government response to the Review recommendations.

We welcome the introduction of the prohibition scheme for disqualified entities but hold concerns about certain aspects especially the notification scheme for practitioners. We reiterate our objections to the Minister having the power to elaborate or supplement the Code of Professional Conduct (the Code) as well as our objection to the inclusion of the concept of “tax system integrity” in the Object of the Tax Agent Services Act 2009 (TASA). As the proposed change to the renewal process will still allow the Board to grant renewal terms of longer than one year, we recommend a staged implementation supported by new systems that minimise the disruption and reduce the burden on practitioners. We support the establishment of the TPB Special Account on the condition that there will be no increase in TPB fees.


  • Published By:The Tax Institute
  • Published On:15 Dec 2022

The material is copyright. Apart any fair dealing for the purpose of private study, research criticism or review, as permitted under the copyright Act, no part may be reproduced by any process without written permission from The Tax Institute.

Unless expressly stated, opinions are not that of The Tax Institute, which accepts no responsibility for the accuracy of any of the information contained within it.

The Tax Institute
(ABN 45 008 392 372 (PRV14016))


The Tax Institute is a Recognised Tax Agent Association (RTAA) under the Tax Agent Services Regulations 2009. 

Copyright Statement

All materials provided on this site are protected by copyright and are owned by or licensed to TTI.

Except as expressly permitted by TTI or the copyright owner, any person or company who uses this site must not use, reproduce, redistribute, retransmit, publish or otherwise transfer, or commercially exploit, the materials or any information, software or other content, in whole or in part, which is available through this site.


Tax administration Consultation Treasury Tax Practitioners Board (TPB)

Share this page