The Tax Institute welcomes the opportunity to make a submission to the Australian Taxation Office (ATO) in relation to the development of the National Tax Clinic program Grant Opportunity Guidelines (the Guidelines).
Assisting vulnerable clients
The National Tax Clinic program plays an important role in providing tax agent services to a range of vulnerable taxpayers who would not otherwise have the ability or option to seek professional advice on their tax affairs. The ongoing skill shortages in the tax profession, combined with the need for taxpayer education in respect of our increasingly complex tax and superannuation systems make the role of the Tax Clinics increasingly important.
In particular, we consider that the Tax Clinics plays a key role in assisting vulnerable taxpayers meet their taxation obligations. Vulnerable taxpayers are often most at risk of not being able to get the assistance they need. Tax Clinics fill an existing and ever expanding hole in the system, and supplement the role of other tax practitioners. The Tax Institute is of the view that Tax Clinics should continue to prioritise supporting vulnerable taxpayers and providing those most in need with free, objective tax advice, and should be supported and empowered to do so.
The nature of a taxpayer’s vulnerability may vary due to their circumstances and can include, but is not limited to, financial vulnerability including those suffering from financial and economic abuse, mental health concerns, domestic violence, physical disabilities, and other disadvantages arising from the taxpayer’s personal circumstances (such as homelessness or imprisonment). We consider that each individual Tax Clinic is best placed to identify the vulnerable clients they can cater to in their geographical location.
Selection and operation of a Tax Clinic
The Tax Clinics are best placed to determine the most appropriate methodology to identify, reach out to, and prioritise those they can assist with their limited resources. Each Clinic would benefit from the freedom to choose the most effective structure, depending on the needs of their taxpayers and the resources available to them. Constraining all Tax Clinics into adopting the same methodology or structure may unintentionally hamper the effectiveness of some clinics.
We consider it important for Tax Clinics to continue to provide their services across Australia and have greater reach in areas of need. It is important for vulnerable taxpayers in both metropolitan and regional areas to be able to access the services of Tax Clinics. Depending on population density and the needs of taxpayers in certain locations, this may require more than one Tax Clinic, or a relatively large Tax Clinic in a given geographic region. The Tax Institute supports additional funding for the Tax Clinic program to better ensure they are able to assist vulnerable taxpayers throughout Australia.
Measuring the success of a Tax Clinic
The success of a Tax Clinic depends on a number of factors, including but not limited to:
- the number of vulnerable clients assisted, and the time able to be allocated to assist them;
- tax education provided to students and taxpayers;
- the ability to provide outreach services to rural and remote communities;
- the ability of the Tax Clinic to identify ways to improve the administration of the tax and superannuation systems; and
- the relationship between the Tax Clinics and the ATO.
Refer to Appendix A for our detailed response.
About The Tax Institute
The Tax Institute is the leading forum for the tax community in Australia. We are committed to shaping the future of the tax profession and the continuous improvement of the tax system for the benefit of all. In this regard, The Tax Institute seeks to influence tax and revenue policy at the highest level with a view to achieving a better Australian tax system for all.