Relevant Experience

If you are completing certain forms published by the Tax Practitioners Board, you may be required to evidence your BAS Experience and Competency. ABN can assist with this by providing you with a Record of BAS Experience and Competency.

What is a Record of BAS Experience and Competency?

Across two distinct eras, ABN and ABN BAS have fostered environments for bookkeepers to accrue vital experience in BAS preparation.

Era #1 – Prior to the commencement of the BAS Agent Laws on 1 March 2010

Australian Bookkeepers Network (ABN) is Australia’s largest private representative body of self-employed and contract bookkeepers. From 1 January 2001 to 28 February 2010, ABN made available to its members a risk-based Quality Assurance Framework which observed the principles enunciated by the Australian Taxation Office in its former Fact Sheet entitled Guidelines for working under the direction of a registered tax agent.

The ABN risk-based Quality Assurance Framework, which was known as the BAS Wizard Partner Program, provided a means by which participating members could provide exempt BAS Services pursuant to S.251L of the Income Tax Assessment Act (1936). The BAS Wizard Partner Program was managed by ABN under the direction of Registered Tax Agents, PT Partners Accountants & Business Advisors Pty Ltd, who hold Tax Agent Number 79285001.

If you participated in the BAS Wizard Partner Program, our Record of BAS Experience and Competency confirms:

• your participation in the BAS Wizard Partner Program; and
• the volume of Activity Statements which you submitted to us for certification in the three years prior to 1 March 2010.

The Record also describes the nature of the BAS Wizard Partner Program and the role played by it in providing a “working under the direction” model for bookkeepers providing BAS services under the former S.251L regime.

Era #2 – Following the commencement of the BAS Agent Laws on 1 March 2010

Since 1 March 2010, ABN BAS has acted as a BAS Agent and provided BAS services to ABN members and their clients. This offering has been underpinned by a quality assurance review process. The role played by the bookkeeper in supporting this quality assurance review process has seen participating bookkeepers accrue further vital experience.

If you have utilised the service offerings of ABN BAS, our Record of BAS Experience and Competency confirms the volume of Activity Statements which you have submitted to us since 1 March 2010.

Click here to view a sample ABN Record of BAS Experience and Competency.

For which Tax Practitioner Board Forms will an ABN Statement of Relevant Experience and Competency Be Useful?

Bookkeepers wishing to provide BAS Services may be applying to the Board in a number of different ways as follows.

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

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

BAS Agent Renewal

To renew your registration as a BAS Agent by 29 January 2012, there are two options. (The reason why 29 January 2012 is the key date is that it is approximately 30 days prior to the end of the transitional period being 29 February 2012).

Section 14 of the Transitional Provisions allows 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 will 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”.

Although under this route you do not need to demonstrate 1000 or 1400 hours, you must still append to the form evidence that you have provided BAS services to a competent standard for a reasonable period. ‘Reasonable period’ is considered to be at least 700 hours in the last two years. ‘Competent standard’ should be demonstrated via a certificate or reference from the applicant’s employer or from the tax agent of the clients for whom the work is done.

The relevant question is Question 15 on the “Application for transitional registration as a BAS agent – individual”, and Question 14 on both the “Application for transitional registration as a BAS agent – partnership” and “Application for transitional registration as a BAS agent – company”.

The question asks “Have you previously provided or are you currently providing a BAS service within the meaning of the Tax Agent Services Act 2009?”. If you formerly participated in the BAS Wizard Partner Program (i.e. prior to 1 March 2010), you should answer this question "Yes". In the space provided, you would then describe the types of BAS Services that you were providing to your clients at that time. If you have provided BAS Services to your clients through another means since 1 March 2010, you could also describe these here. For further information on the types of services that the Tax Practitioners Board consider to be BAS services, please refer to the Tax Practitioner Board Information Sheet entitled What is a BAS Service? which can be downloaded from the Tax Practitioner’s Board web site. Click here to go to the page that links to this Information Sheet.

The question also then makes the following statement: “You will also need to attach evidence that these BAS services were provided to a competent standard for a reasonable period." An ABN Record of BAS Experience and Competency provides such evidence to meet, or contribute towards meeting, your requirements in this regard.

Full registratuon under 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, of which three are nine. 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.

The applicant is required to submit with their application a supplementary document known as a Statement of relevant experience for BAS agent registration. Presently, this document requires that it be completed by the applicant’s supervising tax agent or supervising BAS agent. ABN is not placed to complete this document as the depth of information sought by it goes beyond what a Tax Agent who provided a “working under the direction” model under the former S.251L regime would have. We have communicated this reality to the Tax Practitioner’s Board and await further clarification.

Whether the relationship between ABN BAS and a bookkeeper amounts to supervision and control is unclear. We have sought further clarification on this from the Tax Practitioner’s Board. However, an ABN Record of BAS Experience and Competency will at the very least contribute towards meeting your requirements in this regard.

What is the process for obtaining a Record?

 Simply complete a Request For ABN Record of BAS Experience & Competency.

 To obtain a record, you must be a current ABN member.

 You should allow up to seven days for ABN to produce the Record.

What is the cost of obtaining a Record?

The cost of this service is $55 including GST. Payment options are detailed on the Request form.

How Do I Convert the quantity of Activity Statements certified by ABN into hours?

The time taken to prepare activity statements, and the extent to which this time represents a BAS service as opposed to mere data entry, will vary from person to person. Thus, it is not possible for ABN to extrapolate a number of hours from the volume of activity statements that we have certified for you.

However, by evidencing the volume of activity statements you have submitted to ABN and ABN BAS, and putting forward a basis for approximating the number of hours that underlie each, you will be well placed to quantify your experience.