Introduction

The registration requirements to be a BAS Agent under the Tax Agent Services Act 2009 are based on three criteria.

Firstly, the applicant must be a “fit and proper person”. Secondly, the applicant must satisfy an educational criterion centred on the attainment of a Certificate IV Financial Services (Accounting) or Certificate IV Financial Services (Bookkeeping). Thirdly, the applicant must meet an experience criterion which requires either 1000 or 1400 hours of specified experience in the past three years.

The Certificate IV Financial Services (Bookkeeping) is thus a qualification of key significance to many bookkeepers wishing to provide BAS Services, except those that already hold a Certificate IV Financial Services (Accounting) or a superior qualification ultimately deemed acceptable by the Board.

What Does ABN BAS provide Certificate IV Students who are not yet BAS Agents?

ABN BAS can assist aspiring BAS Agents through a range of offerings:

• ABN BAS can provide BAS services to your clients until you become registered as a BAS Agent in your own right;
   
• Email-based helpline support from our qualified accountants;
   
• Access to the ABN Professional Indemnity (PI) insurance policy which is important given the Code of Professional Conduct requirement that a BAS Agent maintain PI insurance required by the Board; 
   
• Educational material, support services and training sessions that will assist a BAS Agent in satisfying the ‘competence’ provisions enshrined in the Code of Conduct that all BAS Agents must adhere to.

How do I lodge client BASs if I am not yet registered as a BAS Agent?

Since 1 March 2010, a bookkeeper cannot deal with a client’s BAS unless they are a BAS Agent.

If you are a Certificate IV student, it is not necessary for you to relinquish control of your client to a competing bookkeeping firm or Tax Agent. Instead, ABN BAS – as a BAS Agent in its own right – can provide BAS services to your client. This enables you to retain the control of the client relationship. The invoice is rendered by ABN BAS to the client for whom we have provided the BAS Service and bears our Australian Business Number. This makes it explicitly clear that it is ABN BAS, and not the client’s bookkeeper, that is rendering the BAS Service and indeed charging for it. The invoice is paid by the bookkeeper on behalf of the client. The bookkeeper should then recoup this outlay from their client.

Further information on ABN BAS’s Quality Assurance Reviews & BAS Lodgement, including pricing, can be found in the ABN Fact Sheet entitled Quality Assurance Reviews & BAS Lodgement.

How does ABN BAS help me gain experience?

There are two circumstances where you could be seeking to gain relevant experience to assist in your registration as a BAS Agent:

1. Transitional BAS Agent Registration pursuant to Item 14 of the Transitional Act; and
    
2. Full BAS Agent Registration pursuant to Section 20-5 and Schedule 2 Part 1 of the Regulations.

Item 14

Item 14 of the Transitional Provisions allow a bookkeeper to transition as a BAS Agent (for a period of 3 years from 1 March 2010) if they have provided BAS Services to a “competent standard for a reasonable period of time”.

The Tax Practitioners Board has given guidance on the terms competent standard and reasonable period of time. We believe that work you perform where ABN BAS acts as the BAS Agent may satisfy the competent standard requirement. The reasonable period of time requirement has been set by the Board as “at least 700 hours in the last two years”.

ABN BAS can supply a Statement of Relevant Experience and Competency for those that work under the ABN BAS Program. Please visit the Relevant Experience page for more information.

Section 20-5

Where a bookkeeper pursues full BAS Agent registration, the registration criterion for “experience” is that a bookkeeper has at least 1400 hours of relevant experience. This requirement is reduced to 1000 hours if you are a member of a Recognised Tax Agent Association. Included among these are the Institute of Chartered Accountants and CPA Australia

Relevant experience requires that you can demonstrate these hours were gained primarily as “a BAS Agent or Tax Agent, or under the supervision and control of a BAS Agent or Tax Agent, or of another kind approved by the Board." We have sought further clarification from the Tax Practitioner's Board as to whether the working relationship between ABN BAS and the bookkeeper amounts to relevant experience.

ABN BAS can supply a Statement of Relevant Experience and Competency for those that work under the ABN BAS Program. Please visit the Relevant Experience page for more information.

How does ABN BAS help me satisfy the ‘Competence’ requirement of the Code of Professional Conduct?

Item 8 of the Code of Professional Conduct requires that you “maintain knowledge and skills relevant to the tax agent services that you provide”.

ABN BAS and ABN provide many resources that assist a BAS Agent to competently provide BAS Services including the BAS Wizard Quality Assurance framework for BAS preparation, our comprehensive library of Bookkeepers Knowledge Base technical bulletins, website resources, industry newsletters and Pillars of Public Practice (an extensive range of short papers, practical tools and templates to assist bookkeepers achieve business success).

As a further support to a bookkeeper’s skill set and resource base, ABN BAS offers its email-based helpline support from our qualified accountants

How does ABN BAS help me satisfy the ‘Professional Indemnity Insurance’ requirement of the Code of Professional Conduct?

Item 13 of the Code of Professional Conduct requires that you “must maintain the professional indemnity insurance that the Board requires you to maintain”.

ABN has, since 2001, offered its members access to what we believe is the most comprehensive PI insurance product in the market for bookkeepers. Unlike some policies in the market, each ABN policy owner enjoys individual cover. You are not grouped or under an umbrella limit with other bookkeepers. In simple terms, this means that the actions of other bookkeepers in the insurance pool in no way diminish the cover that applies to your policy.

The ABN policy is feature rich and complies with all requirements of the Tax Practitioners Board. Click here to visit our PI Insurance page for more details.