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Tax Practitioner Stewardship Group key messages 16 June 2022

Summary of the key topics discussed at the Tax Practitioner Stewardship Group meeting 16 June 2022.

Last updated 17 January 2023

Welcome and introduction

ATO co-chair Deputy Commissioner Hoa Wood welcomed attendees and thanked them for their valuable contributions to this group. Members were asked if they had any conflicts of interest to be declared (none declared) and reminded the group of confidentiality requirements.

Hoa noted that for Robyn Jacobson, The Tax Institute, this is her first face-to-face Tax Practitioner Stewardship Group (TPSG) meeting and her first meeting as co-chair.

Section 100A Reimbursement agreement guide

Deputy Commissioner Louise Clarke and Assistant Commissioner Chris Ryan have sought feedback on the draft Section 100A Reimbursement agreement guide, to understand how the practitioners may want to use the guide within their practice to enable discussion with their clients.

The guide’s intention is to provide support to the smaller practitioners to have the conversation with clients to explain how they may have to do things differently.

Chris provided a summary of the main points:

  • to educate tax agents that are not familiar with the draft guidance
  • support tax agents with the following    
    • educating their clients about the draft guidance
    • supporting them to maintain appropriate records.

Louise called for any additional feedback to be sent to the TPSG mailboxThis link opens in a new window and advised that communication will be issued prior to tax time, providing additional guidance for tax professionals and trustees. For more information about the draft guidance, see Trust taxation – reimbursement agreement.

Member comments

A member asked that further context for the guide to be provided; the guide is intended for smaller suburban accountants with their first introduction to Section 100A, and not intended for those professionals who have been following the draft.

There is a rumour that there is a $100k threshold under which the ATO will not scrutinise distributions. It was confirmed by the ATO that this is not the case.

Members asked for more examples in the grey areas to be included in the guidance to clarify what was intended by the ATO.

Members noted that this area is very complex and that it is important that tax agents know when they need to get advice from a tax lawyer.

A member advised that the title needs to have specific reference to the 2022 year included in the guidance to alert agents to the critical urgency of the guidance for this tax time.

Advice and guidance

Assistant Commissioner Anthony Marvello highlighted for members the proposed action for Draft Practical Compliance Guideline PCG 2022/D2 Non-commercial business losses - Commissioner's discretion regarding flood, bushfire or COVID-19 where a business activity has been affected.

Anthony advised that Small Business public advice and guidance will continue to focus on producing guidance related to the top 5 topics received for advice and guidance requests. This is intended to ensure that we are focussing our attention on those issues which will make the most impact, with the view of making it easier for tax agents and their clients. This PCG is an example of this approach.

Member comments

Members suggested coupling the PCG with an educational component to help ensure advisers are comfortable with the scope and use the guide to support their small business clients.

Lodge and pay

Assistant Commissioner Claire O’Neill provided an update on an action item from the March TPSG meeting on deferrals and on the awareness campaign on business debt, director penalty notices, as well as offsetting.

Claire advised the peak period for deferral requests at the end of May was not as big as expected. The demand was not there, which meant that deferrals were being processed within standard time frames without additional pressure.

The deferral request and ATO deferral request rejection rate is currently sitting at 3.5%. The top reasons for deferral rejections include:

  • lack of information
  • no reason for request or vague answers that do not make sense
  • incorrect form being used
  • due date has passed.

Assistant Commissioner Kath Anderson confirmed the Lodgment Program Working Group is focussing on the best way to move forward and will discuss lodgment deferrals in a future workshop.

An update was provided to members on the Director Penalty Notice (DPN) awareness campaign, which saw 75,000 letters distributed at the end of March 2022. To date, 23,000 clients who received this letter have taken action, with a majority making payment in full or entering into payment arrangements. Income received from this awareness campaign is currently sitting at $1.7 billion received, and payment arrangements entered for $1.8 billion.

DPN letters are currently being issued at a rate of 100 per day and 300 formal intent to disclosure notices issuing per month. If no response is received from a client, a follow up call is made. At present, a small number of clients are being reported to 3 credit bureaus; these numbers will rise. Claire confirmed disclosure is not automated and does not occur if the client is not aware of the situation.

Reminder letters have been issued to individuals about debts that were on hold due to COVID-19. Taxpayers who have recently had refunds but also have a debt on hold will now be in a situation where those potential refunds will be offset against debts on hold.

Claire confirmed that when the ATO re-raises debts on-hold, the debt raised is equivalent to the credit/refund amount only.

Member comments

Members agree that the strategy behind re-raising debt has been effective, but different terminology could be used to improve the client experience.

Tax Practitioners Board

Debra Anderson, Tax Practitioners Board (TPB), provided an update on work currently being undertaken:

  • There are 487 active cases at various stages; some will be referred to the board conduct committee.
  • The general public has a heightened awareness of the TPB – media campaigns will run again this financial year after last year’s campaign success.    
    • TPB will appear as first search result on Google, reminding taxpayers to make sure they engage registered agents this tax time and there will be an increased social media presence.
  • The TPB provided a timely reminder about cyber safety. The risk at this time of the year is high. Updated guidance has been released to remind practitioners of the importance of being vigilant.
  • From 1 July, new rules on continuing professional education policy (CPE) begin.    
    • The requirement for tax agents is 120 hours over 3 years – an increase from 90 hours over a 3-year period.
    • The requirement for BAS agents is 90 hours over 3 years – an increase from 45 hours over a 3-year period.
    • Both tax and BAS agents should complete a minimum of 20 hours CPE each year – up from 10 hours last year for tax agents and 5 hours per year for BAS agents.
    • CPE hours can align with either TPB requirements or requirements with a professional association; members need to remember what option they select. This means your CPE period can be based on a financial year or calendar year.
  • Fact sheets have been developed for tax agents and BAS agents to provide an overview of the new CPE requirements.
  • For further information see Explanatory Paper TPB(EP) 07/2021 Continuing professional education requirements for tax and BAS agents from 1 July 2022External Link.
  • Cyber security and health and wellbeing (10% capped) is now included within CPE.

Member comments

With the alignment of CPE with the professional associations, a member commented that the definitions are not the same; something to remember. Debra confirmed the CPE can include practice management, not just technical tax for the TPB.

TPSG membership refresh

ATO provided an update on the progress of the membership refresh.

Member comments

A member observed that it’s important to get the most out of the group and members. The value of getting that diversity from different skill bases is valuable.

Several members concurred the importance of profiling prospective members as well as succession planning and bringing in new members who may not contribute immediately but will as they become familiar with the process.

Members raised confidentiality requirements and recommended further clarity on the expectations around who members can/cannot discuss content with.

Tax Time 2022

Assistant Commissioner Kath Anderson advised weekly tax time meetings begin from 28 June and confirmed that usual tax time videos, webcasts and one on one interviews will be available to assist clients from 30 June.

Cyber security was highlighted, specifically to remind practitioners of the importance of myGovID security and not to share their myGovID login details with others within the practice.

Preparation for systems this tax time included:

  • Performance and capacity testing
  • Using the waiting room to manage the increase of demand
  • Focus on performance when accessing the platform this financial year
  • High confidence match on pre-fill data which encourages clients to use the pre-fill data
  • Provision of guidance to assist those making working from home (WFH) and home to work travel claims, with the recommendation being to maintain good record keeping practices; records you need to keep
  • Provision of guidance for taxpayers on the WFH fixed rate method.

Member comments

Some practice accounting software may not be up to date, causing issues accessing pre-fill data.

2030 Tax professionals experience strategy workshop

Assistant Commissioner Kath Anderson and Senior Director Tina Ford-Doe led discussions on the future direction of the Tax Professionals Experience. The Aspiration Statement and Strategic Goals resonated well with all participants and there was robust discussion on initiatives that can be undertaken by all to contribute and meet the objectives.

Several ideas were raised as part of the discussion which the ATO already has underway, demonstrating that we are heading in the right direction to improve the tax professional experience.

A key outcome was identifying what the profession can do to contribute to the strategic goals.

Workshop feedback is being reviewed and will be shared with internal stakeholders prior to finalising the draft document for distribution to TPSG members.

Super and Employer Obligations – Removal of $450 eligibility threshold Super Guarantee

Deputy Commissioner Emma Rosenzweig provided updates, including awareness of the legislated increase of superannuation to 12% by 2025.

From 1 July 2022, removal of the $450 threshold takes effect. Emma noted the following:

  • Employees under 18 years old still have to work for 30 hours to be eligible for the $450 threshold.
  • Employers will need to be aware of the payment date of salary and wages; not when the employee worked.
  • Letters have been issued to employers, and messages distributed via social media and other communications channels.
  • It is imperative for employers to check if their payroll software has auto updated and if not, they need to action updates.

Member comments

A member asked if there is a product that doesn’t need cloud and was advised there are legacy programs that have not been upgraded. Users of legacy systems have been contacted and advised of recommendation to upgrade to cloud.

A professional association member suggested the professional associations could assist with disseminating communication to ensuring the messaging is reaching the community.


Intermediaries Engagement Strategy

Director Ben Spargo provided an update on the Intermediaries Engagement Strategy, advising work is still continuing and that discussion during the workshop will feed into the broader tax agent strategy. Ben also advised myGovID security should always be at the forefront of agents' minds and not to share myGovID login details within the practice.

Lodgment Program Review Working Group

Kath Anderson and co-chair Debra Anderson provided an update on the Lodgment Program Review Working Group. The working group has 3 main focus groups, each presenting robust discussions:

  • Due date pressures – understanding what pressures are being faced and how the pressures can be relieved, especially between July to September when agents are providing add on services to clients
  • Managing exceptions – working through current issues
  • Bigger issues and managing performance – ensuring all stakeholders' needs are being met.

Small Business

Deputy Commissioner Deborah Jenkins provided an update on the new GST Operation Protego. Deborah advised members that in reviewing claims, if no evidence was able to be provided of a taxpayer conducting a business, the ATO would take action to reverse claims made in activity statements. Members were asked to advise the ATO if they have concerns that a legitimate small business may have been inadvertently brought within the activity under Operation Protego.

Information has since been provided to members to share with their networks, including:

Environmental scan

Kath Anderson acknowledged the environment that clients and practitioners, including BAS agents, are continuing to operate in, noting that we continue to receive reports of continued pressure in the profession. She noted that several debt collection activities are being re-introduced across the board, including from banks, credit agencies and landlords.

It has been highlighted, in Lodgment Program Review Working Group discussions, that clients and agents are feeling the pressure in several areas including:

  • ATO lodgment obligations – several reporting deadlines all at once
  • reporting requirements due from both state and federal government
  • uncertainty on requirements due to change in government.

Similarly, it was observed by the group that economic pressures are increasing:

  • interest rate changes
  • energy crisis
  • ATO changes including    
    • Superannuation guarantee
    • Single Touch Payroll Phase 2
    • Client-agent linking
    • heavy reliance on systems.

Deputy Commissioner Australian Business Registers Services Michelle Crosby advised members that 55% of new directors are now using director ID. Compliance activities include nudging directors who have not yet applied. Interesting insights have come out since the project began including:

  • directors unaware they have been made a director
  • phoenix activity / stolen identity.

Member comments

Members advised that it has been a struggle to attract and keep good staff. Smaller boutique accounting firms have noticed larger firms are attracting candidates with larger salaries, creating a large gap in skillsets.

A professional association member noted that a holistic picture of ATO programs of work would be advantageous. Having an understanding of the bigger picture would be helpful to the profession. ATO needs to share strategies behind the programs and continue to communicate and work with the profession.

A member noted the profession as a whole is tired.

Other business

Chair, Hoa Wood thanked members for their engagement and contributions and advised that a call for nominations to join the TPSG under membership refresh process will be advertised in June.


Attendees list




Hoa Wood (Co-chair), Individuals and Intermediaries


Audra Paskevicius (Secretariat), Individuals and Intermediaries


Deborah Jenkins, Small Business


Emma Rosenzweig, Superannuation and Employer Obligations


Grant Brodie, Client Account Services


Kath Anderson, Individuals and Intermediaries


Michelle Crosby, Australian Business Registry Services

Australian Bookkeepers Association

Peter Thorp

Chartered Accountants Australia and New Zealand

Michael Croker

CPA Australia

Elinor Kasapidis

H&R Block

Mark Chapman

Income Tax Professionals

Scott Bailey

Institute of Certified Bookkeepers

Matthew Addison

Institute of Public Accountants

Tony Greco

National Tax and Accountants Association

Rodney Wilson

Tax and Super Australia

Neville Birthisel

Tax practitioner

Keith Clissold

Tax practitioner

Ken Thomas

Tax practitioner

Mark Morris

Tax practitioner

Phil McCann

Tax practitioner

Shanna Hunter

Tax practitioner

Steven Inglis

Tax Practitioners Board

Debra Anderson

The Tax Institute

Robyn Jacobson

Guest attendees

Guest list




Anthony Marvello, Small Business


Chris Ryan, Private Wealth


Claire O’Neill, Lodge and Pay


Julie Gifford, Individuals and Intermediaries


Kerry O’Loghlin, Individuals and Intermediaries


Louise Clarke, Private Wealth


Siobhan Spencer-Arnell, Individuals and Intermediaries


Tina Ford-Doe, Individuals and Intermediaries


Apologies list




Alex Adams, Enterprise Solutions and Technology


Vivek Chaudhary, Lodge and Pay

Tax practitioner

Warren Seeto