SMSF Association Submission – TPB(I) D53/2024 – Breach reporting under the Tax Agent Services Act 2009

SMSF Association Submission

The SMSF Association welcomes the opportunity to provide this submission in response to the Tax
Practitioner Board’s draft guidance TPB(I) D53/2024 – Breach reporting under the Tax Agent Services Act 2009.

The breach reporting provisions will present a number of challenges for registered tax agents (RTA)
when accepting new client engagements. It is uncertain the extent to which agents will be required
to conduct due diligence on the work performed by the previous agent. Often the issue will be
whether the agent holds or has access to sufficient data or information to identify a breach or a
potential breach. Conversely, where cloud software data for a client is transferred from one agent to
another, it may be a case of too much information.

TPB(I) D53/2024 – Breach reporting under the Tax Agent Services Act 2009

SMSF Association Submission