The independence requirements apply to all approved SMSF auditors. However, a number of independence requirements apply specifically to firms and network firms that provide non-assurance services to SMSF audit clients.
Before a firm accepts an engagement to provide a non-assurance service to an audit client, the firm or network firm must determine whether providing the service might create a threat to independence.
Non-assurance services are those services which are not auditing, review or other assurance services, and may include:
- accounting and bookkeeping
- tax and financial planning
- internal audit
- information technology systems
- litigation support
- corporate finance.
A firm refers to either:
- a sole practitioner, partnership, corporation or other entity of professional accountants
- an entity that controls, or is controlled by, one of these entities through ownership, management or other means
- an Auditor-General's office or department.
A network firm is a firm that belongs to a network – being a larger structure that is both:
- aimed at cooperation
- clearly aimed at profit or cost sharing or shares common ownership, control or management, common quality control policies and procedures, common business strategy, the use of a common brand name, or a significant part of professional resources.
For example, the requirements apply to a firm that belongs to a national network of firms with a branch in each state and territory that are aimed at cooperation and share a common brand name. In such cases, independence threats may arise if an auditor conducts an audit for an SMSF client who is receiving other services for the fund from another firm within the network.
Whether a particular arrangement constitutes a network of firms within the meaning of the Code will ultimately depend on the facts and circumstances.
The audit firm is prohibited from providing the non-assurance service where it involves assuming a management responsibility.