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Updating engagement letters, improving due diligence with new clients and capacity planning are some of the areas firms can prepare for the new obligations as they await the TPB's guidance.
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Accounting firms advised on starting points for tackling TASA changes
25 October 2024
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With firms starting to review the upcoming obligations contained in Tax Agent Services (Code of Professional Conduct) Determination 2024), founder of Amanda Gascoigne Consulting, Amanda Gascoigne, and director of BusinessDEPOT, Rebecca Mihalic, said the key to managing the spate of new requirements will be breaking the implementation into smaller, manageable steps.
Speaking in a recent webcast, Mihalic said practitioners are still dealing with a lot of uncertainty in regards to the changes, with the final guidance from the Tax Practitioners Board (TPB) not due to be issued until later this year.
However, Mihalic said there are some areas that firms can start to review to help prepare for the new obligations such as practice management processes, work papers and engagement letters.
CA ANZ has already updated its engagement letter tool which already contains items which are specific to the tasks and changes that are coming up, she said.
"There are paragraphs in there about what to do if you have a dispute or if you have a complaint about your tax agent and also includes links to the TPB website and register. It also has information about how clients can get in contact along with some other updates," Mihalic said.
Mihalic said these were requirements under the first release of the changes that have now been included in her firm's engagement letters.
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"That's one of the key items that we've rolled out almost immediately and it was relatively simple because we use great technology to make that happen," Mihalic said.
Gascoigne said ensuring the firm has up-to-date engagement letters is a great place to start and a good habit to get into for firms regardless of the upcoming obligations.
For firms that haven't previously issued engagement letters or issued an updated one for a while, Gascoigne said the impending changes offer an opportunity or reason to start issuing them.
"Engagement letters help to protect the practice and it's a good habit to get into. Clients may be wondering why they are receiving them if the practice hasn't previously had them or had a robust system around that and might not know how to broach the topic with their clients," Gascoigne said.
"These [obligations] offer a great opportunity to do that."
Introducing better screening or due diligence over potential new clients is another step that firms can take in readying the firm for new obligations, Mihalic said.
"[In our firm] we've implemented a much better process around making sure that we are engaging the right clients."
"When I started my business and particularly in earlier parts of my career, there was always this drive to just increase revenue. We're more concerned now with having the right clients."
Mihalic said this begins with identifying the right clients for the business and then checking that those clients are appropriate.
"We're using BGL ID now to make sure that we're doing identity verification checks which are already required in lots of circumstances to check that those people are who they say they are, particularly in an age where we might not meet everybody face to face," she said.
Accessing the business's accounting records is also an absolute must for Mihalic before she takes on a client engagement, as well as reviewing lodgments.
"I like to get an understanding of where they are before taking them on and if they do have issues such as outstanding lodgements or a huge ATO debt, I don't necessarily say no, but I protect myself by understanding the circumstances and making the right inquiries and taking payment up front," she said.
"We run credit checks on large groups as well because we're hopefully getting into a long-term relationship with these people. We need to make sure they're the right kind of people, and that will hopefully minimise any dispute or any ugliness down the track."
Gascoigne said workflow planning will also be critical as practitioners start reviewing the obligations and planning how to implement the new requirements.
"When I was in practice, we would actually workflow plan all of our compliance work to be done between July and February and that would give us plenty of time for fringe benefits tax, tax planning and other things like that," she said.
Managing workflow is critical for helping to manage stress levels and ensuring clients are serviced well, she said.
Mihalic said there are many tools that firms can use to undertake capacity planning which will map out the work, anticipated revenue and staffing.
"Every year, I spend a lot of time working through that and make sure that we're leaving in time for things such as leave or unknown items that come up, training and education, implementing new technology and just leaving those little gaps where appropriate. We also let our clients know when we're going to start and finish their work."
This kind of planning will be particularly critical this year, she said, as firms may need to allocate time for implementing the new obligations which are due to commence on 1 July.
Gascoigne said firms should consider setting some small milestones now instead of leaving everything to the last minute.
"It's a matter of thinking about what needs to be done and prioritising time to ensure that those things get done."
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