ABN BAS FAQs

For Non-BAS Agents

For Non-BAS Agents, ABN BAS can assume the role of BAS Agent for your clients and attend to the review, preparation and electronic lodgement of their Activity Statements with the ATO.

The first step in the process is to download the BAS Wizard from the ABN BAS Member Centre. The BAS Wizard is a sophisticated Microsoft Excel tool, developed by ABN BAS for the exclusive use of our members. The BAS Wizard comes with a user guide, support notes, and sample files for you to practise with.

Once you are familiar with the BAS Wizard, the main process is as follows:

• You enter your client’s data into the BAS Wizard and insert any necessary reports (preferrably in PDF).
• The BAS Wizard has a range of inbuilt integrity checks that will alert you to possible errors to be amended prior to submitting your file for review. You review these checks and ensure that all is in order.
• You have your client sign the BAS Agent authority (first lodgement only) and the client authority (every lodgement), which are both required prior to lodgement of the client's Activity Statement. Both of these documents can be accessed via the BAS Wizard—you simply print them out, obtain your client’s signature, then scan them and insert them into the BAS Wizard.
• You submit the file to ABN BAS via our secure file transfer facility, Safe Passage.
• ABN BAS will perform a Detailed Quality Assurance Review on the file, work with you to correct any errors, and then lodge the BAS.

For BAS Agents

For BAS Agents, ABN BAS can perform either a Detailed or Limited Quality Assurance Review of any Activity Statements that you will be lodging, so as to provide you with a second opinion and some peace of mind.

The review process for BAS Agents is essentially the same as the process for Non-BAS Agents detailed above, with the exception that ABN BAS will not require the signed authorities from the client as we will not be lodging the BAS.

For further information on the ABN BAS Quality Assurance Review & BAS Lodgement process, including our prices, turnaround times, and payment and invoicing, please click here.

A Detailed Quality Assurance Review (which is mandatory if ABN BAS is acting as the BAS Agent for your client) entails the following:

• We perform a range of reconciliations, proofs and integrity checks based on the information you have entered into BAS Wizard.
• We verify many of these figures by referring to reports and source documents that we ask you to insert into Attachment sheets contained within BAS Wizard.
• We also check the postings for certain Reviewable Transactions against source documents which we ask you to attach. Examples of Reviewable Transactions include the purchase or sale of a business, and the purchase of a capital asset under a finance instrument.

• Upon completion, we email you an “ABN BAS Declaration” to confirm we have conducted a Detailed Quality Assurance Review on this Activity Statement. If ABN BAS is to be the BAS Agent for your client, we will also email you a copy of the BAS that was electronically lodged with the ATO.

 
The time you spend in interacting with ABN BAS as part of the Detailed Quality Assurance Review process will count as relevant experience. This is the case whether you are lodging a BAS as an employee on behalf of your employer, or lodging a BAS as a self-employed or contract bookkeeper on behalf of your client.

A Limited Quality Assurance Review is less rigorous than a Detailed Review. A Limited Review still entails a range of arithmetical checks and reconciliation checks, but doesn’t involve an examination of individual transactions.

If ABN BAS is not going to be acting as the BAS Agent for your client, you may choose whether you would like a Detailed Quality Assurance Review or a Limited Quality Assurance Review. Scenarios where this might be at play include:

• you are an employee lodging a BAS on behalf of your employer. There is no requirement on you to be a Registered BAS Agent in order to lodge your employer’s BAS.

• you are a self-employed or contract bookkeeper and another Registered BAS Agent or Tax Agent will be lodging your client’s BAS.

The time you spend in interacting with ABN BAS as part of the Limited Quality Assurance Review process will not count as relevant experience, regardless of whether you are lodging a BAS as an employee on behalf of your employer, or lodging a BAS as a self-employed or contract bookkeeper on behalf of your client.

ABN BAS will complete the Quality Assurance Review & Lodgement of your BAS Wizard file by no later than 5pm on the seventh business day following the date you submitted the file to us. This turnaround time is based on the BAS Wizard file not requiring re-submission due to errors or omissions.

Business days are from Monday to Friday, and do not include:

• any days that are a public holiday in Queensland.
• the Christmas/New Year period that ABN is closed. (We will advise you each year of the exact dates of our closure.)

If one or more of the days in your file’s review period are a Queensland public holiday or within the Christmas/New Year period, then please add the corresponding number of days to your turnaround time.

For Detailed Quality Assurance Reviews, our price is $77 for Business Activity Statements and $25 for Instalment Activity Statements. An Electronic Lodgement Fee of $22 applies in instances where ABN BAS is the client’s BAS Agent.

Additional fees apply if there are any “Reviewable Transactions” in existence, reflecting the checking and verification that ABN BAS must attend to. Each instance of a Reviewable Transaction will attract the following fees, with the exception of Imports where a customs broker has outlaid GST on your behalf, in which case it is the existence of this that gives rise to the additional fee, not the number if instances

Before you submit the BAS Wizard file to ABN BAS, you will be aware of the precise cost of our service as BAS Wizard will have calculated that for you.

For Limited Quality Assurance Reviews, our price is $36.30 for Business Activity Statements and $18.15 for Instalment Activity Statements.

We also offer a range of Supplementary Services. For a description of each of these services, please click here.

As a tax invoice is sent when each BAS lodgement is completed; however, you do not pay this invoice. On or around the 1st business day of the following month, a statement totalling all of the previous month’s activity will be emailed to you, and this total will be direct debited from your nominated account around the 21st day of the same month.

In the payroll realm, it is important to note that the Tax Practitioner Board (TPB) view the following as “BAS Services”:

• Confirming the withholding tax obligations for the employees of a client;
• Preparation and provision of a payment summary that may include reportable fringe benefits amounts and the reportable employer superannuation contributions;
• Registering or providing advice on registration for PAYG withholding.

In respect to the first point—that of confirming the withholding tax obligations of a client—if you utilise our Quality Assurance Review and BAS Lodgement program for a particular BAS for a particular client, then ABN BAS will review the PAYG Withholding items recorded on that BAS. This entails us checking that Gross Payments, Deductions and Amounts Withheld can be proven by reference to the Payroll Reports within the client’s accounting software. As the BAS Agent responsible for lodging that particular BAS, we become the entity that is reporting these numbers to the ATO.

However, in respect to the second and third points, ABN BAS does not offer these services. If you are not a BAS Agent in your own right, then you will need to utilise another BAS Agent or Tax Agent to provide these services to your clients. That BAS Agent or Tax Agent may choose to provide these services to the client by utilising you, on the basis that they have a supervisory arrangement with you.

The Tax Practitioner Board (TPB) provides an information sheet on Supervisory arrangements and supervision and control which explains their views on this matter. In that sheet, they state that “there is no precise definition of what constitutes adequate supervisory arrangements or supervision and control. What is adequate will be a question of fact to be determined on the basis of the specific facts of a particular case”. Thus, in each such scenario where a non-BAS Agent and a BAS Agent or Tax Agent form a relationship for the provision of payroll services to a client, the adequacy of the supervisory arrangement at play will need to be considered in the light of the TPB’s information sheet.

However, insofar as payroll services (including superannuation) are concerned, any interactions that we have with our members will not amount to “supervision and control”. Indeed, for a given BAS for a given client, there is a step within our Quality Assurance Review and BAS Lodgement program that sees an intersection of sorts between your services and ours; however, this does not meet the level of “supervision and control” as discussed in the aforementioned TPB information sheet. Consequently, if you are providing payroll services (including superannuation) to your clients, you should ensure you have an arrangement in place with a Registered Tax Agent or BAS Agent that meets the level of “supervision and control” as discussed in the aforementioned TPB information sheet.

Available from within the ABN BAS Member Centre, you can access our GST & PAYG Ready Reckoner. This is the pre-eminent industry reference for GST coding, PAYG withholding and PAYG instalment. It contains hyperlinks to the relevant ATO fact sheets and ABN Bookkeepers Knowledge Base editions, instructions on the likely tax code to be used across the five major accounting software packages, and information on which labels on BASs and payment summaries are affected.

ABN BAS also provides a service where, at a fixed fee of $220, we can perform a Quality Assurance Review on the Chart of Accounts and the default GST codes that you have created for a particular client. We will then provide you with confirmation that the Chart of Accounts is to our satisfaction, or provide you with recommendations for change, as the case may be. To access this service, please visit our Supplementary BAS Services page in the Member Centre to request the service.

If you are not a BAS Agent in your own right, it has always been the stance of ABN BAS that you need to utilise another BAS Agent or Tax Agent to provide you with a supervisory arrangement when it comes to the payroll services that you may provide to your clients. The Tax Practitioner Board (TPB) provides an information sheet on Supervisory arrangements and supervision and control which explains their views on this matter.

The advent of Single Touch Payroll (STP) has reinforced this imperative. This is because, under STP, each time a pay run is processed using STP-compliant software, information will be reported directly to the ATO. The reporting of any such information needs to be in keeping with an “STP engagement authority”, which is a written authorisation (in an approved ATO format) evidencing a registered agent’s authorisation to prepare STP pay events on behalf of an employer.

Consequently, if you are not a registered agent in your own right, you are not able to enter into a STP engagement authority with a client. Therefore, non-agents that are involved in the processing of payroll would need to ensure that:

1. There is an adequate supervisory arrangement in place between themselves and a registered agent; and
2. There is an “STP engagement authority” in place between the registered agent providing the supervisory arrangement and the client.

Further information on the “STP engagement authority” is available from the ATO web site.

The approach taken by ABN BAS when performing its Quality Assurance Review and Lodgement will be unchanged. We will continue to require that the same payroll reports be inserted into BAS Wizard as is presently the case.

It is simply that from 2020, labels W1 and W2 on the BAS for small to medium withholders are expected to be pre-filled by the ATO based on the STP data that has been transmitted to them during that period. If and when that pre-filling becomes a reality, we will advise further as to the changes (if any) that will apply to PAYG-W reporting within BAS Wizard.

If you would like to get further up to speed on all things STP related, please make use of the following ABN Resources:

ABN Fact Sheet –Single Touch Payroll Survival Guide
ABN Resource – The Buzz 14 Feb 2019 – Single Touch Payroll Deadline – Three Month Grace Period

The starting point is that it is almost impossible to provide a payroll service to clients without providing as a BAS service when doing so (Superannuation Guarantee and PAYGW are BAS Services). BAS services of course can only be undertaken by BAS Agents or Tax Agents (or under the close supervision and control of a Tax Agent or BAS Agent). One option is to limit your client engagements by excluding payroll services from your offering.

Payroll-based BAS services can also be undertaken by an employee/owner of a business on behalf of that business (for example, a non BAS Agent employee of XYZ completing the Activity Statement for XYZ).

Therefore, what are the options on how a Non BAS Agent can facilitate payroll-based BAS Services for their clients?

Option 1:
Outsource the payroll to an external company.

Outsourcing the payroll function to a payroll bureau or payroll service is a valid solution. There are plenty to choose from but you should check the reputation of the provider and that the outsource provider is registered with the TPB. You may be able to offer that client your own payroll services once you are registered and you are comfortable in rendering a payroll service.

Option 2:
Become an employee of your client.

Whilst this option may not be suitable for all Non-BAS Agents, it is a legal method of providing payroll services. You are not personally charging a fee for BAS services; therefore, you are able to complete all facets of payroll whilst working towards your own BAS Agent registration.

Option 3:
Complete the payroll services as a contract bookkeeper whilst being supervised by another BAS or Tax agent.

It is not practical for ABN BAS to offer a supervisory service around the payroll function. The processes involved, the background payroll information and detailed client knowledge required would render the service uneconomic to both your client and ABN BAS. If you are not a BAS Agent in your own right, it has always been the stance of ABN BAS that you need to utilise another tax or BAS Agent (normally the client’s accountant) to provide you with a supervisory arrangement when it comes to the payroll services that you may provide to your clients. The Tax Practitioner Board (TPB) provides an information sheet on Supervisory arrangements and supervision and control, which explains their views on this matter.

The advent of Single Touch Payroll (STP) has reinforced this imperative. This is because, under STP, each time a pay run is processed using STP-compliant software, information will be reported directly to the ATO, which constitutes a BAS Service. The reporting of any such information needs to be in keeping with an “STP engagement authority”, which is a written authorisation (in an approved ATO format) evidencing a registered agent’s authorisation to undertake STP pay events on behalf of an employer.

Consequently, if you are not a registered agent in your own right, you are not able to enter into an STP engagement authority with a client. Therefore, non-agents that are involved in the processing of payroll would need to ensure that:

1. There is an adequate supervisory arrangement in place between themselves and a registered agent; and
2. There is an “STP engagement authority” in place between the registered agent providing the supervisory arrangement and the client.

After receiving various requests, we have created an STP Agent Letter Template for our Non-BAS Agent members to utilise when formalising the supervisory arrangement between themselves and the registered agent. This template is located in the ABN Members section under STP Engagement & Finalisation Authority Templates.

If you are a BAS Agent, then you are required under the Tax Agent Services Act 2009 (TASA) to maintain PI insurance to a level that meets the requirements of the Tax Practitioners Board (TPB).

If you are not a BAS Agent, then no such requirement exists; however, it is our view that PI Insurance is a commercial necessity and to operate without it when providing bookkeeping services to the general public (even if they are not BAS Services per se) is foolhardy.

ABN BAS, as a BAS Agent in its own right, carries its own comprehensive PI insurance, but this policy does not cover other parties.

However, we are pleased to offer members access to what we believe are comprehensive PI Insurance products on the market for bookkeepers. For information on the providers polices and how to apply, visit our PI Insurance page.

Yes. You will need access to a PC with a full version of Microsoft Excel. Mac-based or trial versions of Excel will not be sufficient.

The ABN BAS Quality Assurance Review and Lodgement service is underpinned by the BAS Wizard, an Excel-based tool that uses Visual Basic for Applications (VBA) to generate macros for automation and ease of data entry. The extent of Visual Basic in BAS Wizard is quite substantial. Unfortunately, older Mac-based versions of Excel do not support Visual Basic, while newer Mac-based versions carry with them a substantial number of differences in how Excel itself behaves, and how VBA interacts with the Mac platform. Similarly, trial versions of Excel do not support VBA and thus much of the functionality that is integral to BAS Wizard is rendered unusable. 

It is necessary that accounting software is utilised in order to be able to produce the GST and PAYG reports required to substantiate the amounts entered into BAS Wizard. 

This is due to the fact that accounting software is generally based on a double entry bookkeeping system, whereby every financial transaction has equal and opposite effects in at least two different accounts. Reconciliations such as bank, credit accounts, debtors and creditors should be performed prior to commencing the preparation of the BAS to confirm accuracy of the transactions. Additionally, the extraction of the required reports by PDF from accounting software reduces the risk of changing financial information, and therefore is a more secure option.

Our Fact Sheet "Inserting Attachements into BAS Wizard" provides you with instructions on how to insert the PDF reports, in addition to the required reports for the major accounting software companies.

ABN BAS, as a registered BAS Agent, is legally able to represent a client in dealings with the Commissioner of Taxation, such as a GST audit.

However, we do not offer such a service as it is our position that representation in an audit is more appropriately performed by the client’s Registered Tax Agent. Our rationale for taking this position is that GST audits invariably cut across multiple aspects of a client’s tax affairs, including income tax and Fringe Benefits Tax. The client’s Registered Tax Agent will be better placed to have an overall understanding of the client’s tax affairs. 

A client must provide a written and signed declaration, known as an Activity Statement Lodgement Declaration, for each activity statement lodged on their behalf by a BAS Agent or Tax Agent. If you indicated in Sheet 1 of BAS Wizard that ABN BAS will be the BAS Agent that will lodge this BAS with the ATO, the Activity Statement Lodgement Declaration will be tailored with our details. Otherwise the Activity Statement Lodgement Declaration will not be available to produce. In order for ABN BAS to represent a client in dealings with the ATO, it must hold a BAS Agent Authority. This is required once only at the point in time that ABN BAS first acts as BAS Agent for the client

Yes. It is not necessary that you obtain a “wet” signature from your clients on these documents. Instead, your clients can view the documents electronically and insert a digital image of their signature. It is not however permissible for you to merely hold a copy of a digital image of the client’s signature and insert it on their behalf, because this practice would mean that the client has not been afforded the opportunity to review and approve the specific documents.

In the case of a company, it should be a company director.

In the case of a trust, it should be a trustee (or in the case of a corporate trustee, a director of the corporate trustee).

In the case of a partnership, it should be a partner. If a partner is a company or trust, then refer to the aforementioned comments on companies and trusts. 

Firstly, Section 90-5 of the Tax Agent Services Act states

A tax agent service (includes BAS Services) is any service that relates to:

• ascertaining liabilities, obligations or entitlements of an entity that arise, or could arise, under a taxation law
• advising an entity about liabilities, obligations or entitlements of an entity or another entity that arise, or could arise, under a taxation law
• representing an entity in their dealings with the Commissioner of Taxation, and

is provided in circumstances where the entity can reasonably be expected to rely on the service for either or both of the following purposes to:

• satisfy liabilities or obligations that arise, or could arise, under a taxation law
• claim entitlements that arise, or could arise, under a taxation law.

Therefore, if the client is reasonably expecting to rely on the service you have provided in relation to the above dot points, then you would need to be registered as a BAS Agent. If the client is reliant on the accountant, who is ultimately responsible for the above dot points, then there is no need to be registered but the onus would be on the accountant to have appropriate supervision of your work. It is not necessary that you are an employee or contractor working directly for the accountant. The TPB have published a Fact Sheet (extract below) dealing with contractors.

Options available to contractors https://www.tpb.gov.au/contractors-tpb-information-sheet-tpbi-132012

20. If a contractor is not providing a tax agent service or BAS service for a fee or other reward, they will not be required to register with the TPB.
21. However, if a contractor intends to provide a tax agent service or a BAS service for a fee or other reward, the following options are available:

• Subject to meeting the eligibility requirements, the contractor could register as a tax agent or BAS agent.

For individual registration, this includes being a fit and proper person and having appropriate qualifications and relevant experience.
For partnership or company registration, this does not necessarily require the person providing the service, for example the employee, to be registered in their own right. The partnership or company can be registered if they have a sufficient number of registered individuals, being registered agents, to provide tax agent services to a competent standard and to carry out necessary supervisory arrangements.

• The contractor could work for a registered tax agent or BAS agent.

This requires the contractor to perform services for the registered agent who then provides services to the client for a fee or other reward. The registered agent must comply with its obligations under the Code, including ensuring that any tax agent service it provides, or that is provided on its behalf, is provided competently. In addition, the registered agent must also ensure all civil penalty obligations under the TASA are met including that they supervise and control relevant work that the contractor does.
It would be absolutely essential that there is a visible three-way relationship in place. The accountant would need to acknowledge that they are ultimately responsible for the rendering of BAS services (lodgement and advice), the client needs to be aware of this relationship and both client and accountant need to be aware that your work is being supervised by the accountant. It is best this is in writing to eliminate any confusion between the parties.

Another option of course if you are wishing to gain relevant experience while facilitating BAS Services under ABN BAS to work towards your own BAS Agent registration, is to utilise our QA Reviews & BAS Lodgement program

The due date for a quarterly BAS is usually as follows.

The due date for a monthly BAS is usually on the 21st day of the following month.

If the due date is on a weekend or public holiday, you can lodge your form and make any payment due on the next business day.

Additionally, if you lodge your quarterly activity statements online, you may qualify for a two week deferral of your activity statement due date. This offer is ongoing and is subject to a range of terms and conditions. Click here to visit the ATO web site for specific details on the two week deferral offer.

These dates are established annually by the ATO as part of their BAS Agent Lodgement Program.

Broadly speaking:

• There are no extra concessions for monthly activity statements, with the exception of the December activity statement which is due by 21 February rather than 21 January;
• There is a 4 week concession for quarterly activity statements, with the exception of the December activity statement as its due date is already four weeks later for everyone.

For BAS Agents to be eligible for these concessions, lodgement must take place via either the BAS Agent Portal, Standard Business Reporting (SBR) or Electronic Commerce Interface (ECI).

Click here to visit the ATO web site for specific details on the BAS Agent Lodgement Program.

Yes. ABN BAS is a registered BAS Agent and is therefore eligible for the concessions granted by the ATO as part of their BAS Agent Lodgement Program.

Thus, the lodgement dates for clients of ABN BAS are as follows:

• There are no extra concessions for monthly activity statements, with the exception of the December activity statement which is due by 21 February rather then 21 January;
• There is a 4 week concession for quarterly activity statements, with the exception of the December activity statement as its due date is already four weeks later for everyone.

There are a range of factors that will influence whether penalties and/or interest are imposed. These include, but are not limited to:

• the extent of the lateness;
• the financial outcome of an Activity Statement;
• the lodgement history of the client;
• the existence of extenuating circumstances.

 
A comprehensive discussion of the ATO’s penalty and interest regime can be found on the ATO’s website by clicking here.

ABN BAS can assist with the seeking of Lodgement Deferrals and Penalty/Interest Remissions in some circumstances. Further information on these services can be found on the Supplementary Services page within the ABN BAS Member Centre. 

Yes. In instances where ABN BAS is being asked to provide BAS Services to your client, it is an ATO requirement that we hold the appropriate permission from the client. This permission takes the form of a “BAS Agent Authority”.

For Quality Assurance Reviews & BAS Lodgement, the BAS Agent Authority is referred to within BAS Wizard, the Excel-based software that is used as the platform for the process itself. The BAS Agent Authority referred to within BAS Wizard must be provided on the first occasion that a Quality Assurance Review & BAS Lodgement takes place for a particular client.

However, ABN BAS also offers a range of Supplementary BAS Services and it is possible that you may request one of these services for a client who has not yet utilised ABN BAS for a Quality Assurance Reviews & BAS Lodgement. In these situations, a BAS Agent Authority is required to be completed by your client before we can provide the requested service. Templates for the BAS Agent Authority are available in both PDF and Word formats in the ABN BAS Member Centre.

A Detailed Quality Assurance Review is not available for any clients operating in “Complex Industries” as the degree of supervision and control needed would be too great for our service to remain price-competitive.

The following lists the clients who fall outside the scope of ABN BAS’s due to operating in “Complex Industries”:

• The client offers insurance either as an insurer or underwriter (insurance underwriters evaluate the risks and exposures of potential clients). This includes any type of insurance, irrespective of whether it is taxable (general insurance), GST-free (health insurance), or input taxed (life insurance).

• The client is a second-hand goods dealer (i.e. any person or other entity who carries on the business of buying, selling, exchanging or otherwise dealing in second-hand goods i.e. goods that are not new e.g. Cash Converters etc.)

• The client makes financial supplies which are partly or wholly input taxed.  These would include for instance supplies such as loans, share trading, securities, hire purchase arrangements, life insurance etc. 

• The client's core business is the buying, selling or developing of property (excludes real estate agents)

• The client’s business involves the importation of goods from overseas using the Deferred GST scheme. GST is usually payable to the Australian Customs Service at the time imported goods are released from customs for use in Australia (home consumption). Subject to certain eligibility criteria, however, if you are an importer who is registered for GST, you may be able to defer the payment of GST on imported goods by participating in the Deferred GST Scheme. The scheme basically means that the GST can be deferred until the first Activity Statement is submitted after the goods have been entered for home consumption

• The client operates a retirement home or similar aged-care accommodation such as a nursing home etc.
• The client is a food retailer who uses a simplified accounting method for GST purposes (SAM). Without SAMs food retailers may when it comes time to fill in the BAS find themselves in the position of having to distinguish between food and drinks which are taxable, GST-free or a mixture. This can be complicated. SAMs allow food retailers to use estimates as a substitute for actual sales figures, and thus reduce the GST compliance burden. There are 3 main types of SAMs available. – Business Norms Method, Snapshot Method, and Stock Purchases Method.
• The client is a self-managed superannuation fund.
  
• The client is a not-for-profit organisation other than a child care provider. Not for profits are organisations that are not operating for the profit or gain of individual members – both while the organisation is operating and when it is wound up. Any profit goes back into the operation of the organisation to carry out its purposes and is not distributed to members. The constituent or governing documents of the organisation will generally prevent the assets or profits from being distributed to particular people.
• The client is involved in a GST group, GST branch or GST joint venture:
  
  • GST Groups consist of two or more businesses that operate as a single business for GST purposes. To form a group, the businesses must satisfy certain requirements and notify the ATO of the formation of such a group
  • GST Branches – A business may operate through GST branches. Even though they are not separate entities (i.e. they have the same TFN etc.), branches account for GST separately. A business may find it advantageous to register as a branch with the ATO where for example it operates out of various locations (stores) or has different business lines. Rather than amalgamating the accounts of each store every BAS period, the branches account for their own GST as though they are separate entities. 
  • GST Joint Venture is where two or more businesses combine their resources, knowledge and skills to achieve a specific commercial outcome. If certain requirements are met, you can apply to the ATO to be registered as a GST Joint Venture. The nominated Joint Venture operator then deals with the GST liabilities and entitlements arising from its dealings, in the course of activities for which the Joint Venture has entered into, on behalf of all the participants in the Joint Venture.

• The client collects Wine Equalisation Tax (WET). This is a value-based tax which is added to wine consumed in Australia. WET is charged at a rate of 29% and is applied to the final wholesale sale of wine before GST is added. That is, Retailers of wine pay WET in the price they pay their suppliers for wine. WET is then remitted to the ATO by the Wholesaler.

• The client collects Luxury Car Tax (LCT). This is a tax imposed on cars with a GST-inclusive value above the luxury car tax threshold ($75 526 for 2016/2017). LCT is paid by businesses that sell or import luxury cars (dealers), and also by individuals who import luxury cars.

A good way to describe this in your promotional material or advertising is to state that you work with ABN BAS to “facilitate” BAS Services for your clients.

The word “facilitate” is a reasonable one to use in describing the situation where you, as the non-BAS Agent, have enabled a solution for your client that results in a BAS Service being provided to them by a Tax Agent or BAS Agent. The definition of “facilitate” (according to Merriam-Webster) is “to make (something) easier or to help cause (something)” which, in essence, is what a non-BAS Agent is doing in situations where they work with a Tax Agent or BAS Agent to bring about the provision of BAS Services for their client.

The Tax Practitioner’s Board have confirmed that if bookkeepers wish to advertise that they can facilitate the provision of a BAS service by a registered BAS agent, they should include the full name and registration number of the registered agent on their advertisements.  Although this may go beyond any legislative requirement, it would be seen by the TPB to be the ideal style of advertising for this particular arrangement between a bookkeeper who is not a registered BAS agent and a registered agent, and it would avoid any further enquiries by the TPB. You should make it clear to the client that ABN BAS Pty Ltd, Registered BAS Agent #91970004,  is providing the BAS Service and not you.

The client will also need to sign a BAS Agent Authority when appointing ABN BAS Pty Ltd. as their BAS Agent. This form in itself is a good way to evidence that there is, in fact, another party in the mix. Over and above this, we also recommend that your engagement letter with the client makes clear the existence and role of the Tax Agent and BAS Agent, and the fact that you cannot provide BAS Services in your own right.

By visiting the ABN BAS Logos page, you can download a logo which depicts the “working with ABN BAS” arrangement described above. 

You cannot use ABN BAS’s TPB symbol in your advertising for the following reasons:

• the TPB has clear guidelines that dictate the use of registered practitioner symbol. The terms and conditions for use of the registered practitioner symbol can be found on the TPB website.  Specifically, clause 9.1 states that ‘You agree not to assign or sub-license your rights to use the symbol’.
• in addition to the terms and conditions, there are restrictions on the use of the registered agent symbol under the Registered tax practitioner symbol certified trade mark rules. Paragraph 77 of these rules sets out the restrictions on using the symbol, including that the symbol must only be used in, or in connection with, the provision of tax agent services, BAS services or tax (financial) advice services for a fee or other reward by, or on behalf of, a registered tax practitioner.

However, by visiting the ABN BAS Logos page, you can download a logo which depicts the “working with ABN BAS” arrangement.

Under the Tax Agent Services Act 2009 (TASA), if you are not a registered Tax or BAS Agent, you must not charge or receive a fee or other reward if you provide a service which you know or should reasonably know is a BAS service. 

Therefore, if you are not a BAS Agent and are merely facilitating a BAS Service for your client through a Tax Agent or BAS Agent (such as ABN BAS), there are a couple of key points to bear in mind.

Firstly, you should make it clear to the client that it is the Tax Agent or BAS Agent that is providing the BAS Service and not you. The client should be asked to sign a BAS Agent Authority when appointing the Tax Agent or BAS Agent to provide BAS Services, and this form in itself is a good way to evidence that there is, in fact, another party in the mix. Over and above this, we also recommend that your engagement letter with the client makes clear the existence and role of the Tax Agent and BAS Agent and the fact that you cannot provide BAS Services in your own right.

Secondly, you should ensure that you do not invoice the client, directly or indirectly, for the BAS Service that has been provided by the Tax Agent or BAS Agent; it would be illegal to do so. You may, however, directly pass on to the client, or seek reimbursement from the client, for the costs associated with an invoice received from the Tax Agent or BAS Agent for the BAS Service.

By “pass on”, we are referring to the situation where you take, for example, the ABN BAS cost which you have incurred on behalf of your client, and you include this cost within your invoice as an expense outlaid on their behalf, attaching a copy of the ABN BAS invoice when doing so.

For example, your invoice might appear as follows:

This approach is not dissimilar to other commercial scenarios where a service provider is merely paying an expense on behalf of a client, and later recovering it from the client. To give some more examples:

• An accounting firm may pay a lawyer on behalf of a client to prepare a legal agreement for the client, and will later recover this cost from the client by attaching the lawyer’s invoice. The accounting firm is not providing legal services per se, but is merely facilitating the preparation of the legal agreement.

• An interior designer may acquire furniture on behalf of a client and will later recover this cost from the client by attaching the furniture retailer’s invoice. The interior designer is not producing furniture per se, but is merely facilitating the procurement of the furniture from a retailer.

By “reimbursement”, we are referring to the situation where you merely forward the ABN BAS invoice directly to your client (as opposed to incorporating it within your own invoice as described above). When doing so, you would point out that you have paid the invoice on their behalf and you would request that the client merely reimburse you for that amount.

While you may not directly charge for BAS Services, you may directly charge for general bookkeeping services (i.e. non-BAS Services) and you may also charge for BAS support services when working with a BAS Agent or Tax Agent who is responsible to the client for the BAS Services. In the case of working with ABN BAS, it would be acceptable to charge for your time in preparing the information that ABN BAS requires in order to prepare and lodge the BAS. This time would include completing the BAS Wizard file and supplying it to us. However, when charging for BAS support services, you must not state or intimate that you are a BAS Agent.

Whether you choose to charge for general bookkeeping/BAS support services by way of an hourly rate, a fixed price, or as part of an overarching retainer arrangement will come down to the pricing model that you adopt within your business and the billing arrangement you have with the particular client.

Here are the key messages to get across to your client:

1. Since 2010, legislation known as the Tax Agent Service Act has meant that only registered Tax Agents and BAS Agents can legally prepare a BAS for a fee.
2. For various reason (which you may or may not choose to divulge), you are not a BAS Agent in your own right.
3. You are, however, a member of Australian Bookkeepers Network, a national organisation that provides support tools, resources and a network of experts that enable bookkeepers to make well-informed strategic business decisions and stay ahead in their industry.
4. ABN’s sister company, ABN BAS Pty Ltd, is a registered BAS Agent that provides BAS Services exclusively to ABN members and their clients. The BAS Agent Registration Number of ABN BAS Pty Ltd is 91970004.
5. Even though you are not a BAS Agent in your own right, you are able to “facilitate” BAS Services for your clients through ABN BAS.
6. You will deal directly with ABN BAS on the client’s behalf, which enables the client to continue to maintain just the one bookkeeping relationship with you, while at the same time enjoying the peace of mind that comes from knowing their BAS has been reviewed and lodged by a registered BAS Agent.

Yes. In BAS Wizard, Sheet 2 – GST Checklists, steps 2 and 3 require you to thoroughly review the tax codes that have been assigned to purchases and sales, respectively. Moreover, in Sheet 13 – Finalisation, step 4 includes a checkbox where you must attest to the fact that you have reviewed the GST treatment of transactions throughout the period.

Our BAS Wizard software, at Step 4 of Sheet 1, distinguishes between the following lodgement scenarios:

1. ABN BAS will be the BAS Agent that will lodge the BAS with the ATO 
2. The Business that the BAS relates to is your own business and will lodge its own BAS with the ATO 
3. Another BAS Agent or Tax Agent or your employer will lodge the BAS with the ATO Your answer will influence the type of quality assurance review that is to be performed and the cost.

In the case of scenario 1, a Detailed Quality Assurance Review is required, and a $22 lodgement fee will be added to the total price of our service. 

In the case of scenarios 2 and 3, either a Detailed Quality Assurance Review or Limited Quality Assurance Review can be requested, and a $22 lodgement fee will not be added to the total price of our service. 

In the case of scenario 3, however, you will also be prompted to advise us either of the name of the BAS Agent or Tax Agent that will be lodging the BAS, together with their BAS Agent or Tax Agent Number (or if you are an employee lodging the BAS for your employer, the name of your employer). 

Please note that the following scenario is in breach of the Tax Agent Services Act and is therefore not listed as an option in BAS Wizard: 

• you prepare a BAS for a client (who is not your employer) using BAS Wizard and have a Quality Assurance Review performed by us; and 
• you or your client lodge the BAS either in paper form or through the client’s own Business Portal.

*Please note that in terms of gaining relevant experience towards a BAS Agent registration, only the work that you perform in relation to a Detailed Quality Assurance review will count.

If you are not a BAS Agent, ABN BAS can provide BAS Services for your clients through a structured program which we refer to as Quality Assurance Reviews & BAS Lodgement. The program is underpinned by the BAS Wizard, a sophisticated Microsoft Excel tool that was designed and created by ABN BAS. Broadly, you enter key information for your client’s BAS into the BAS Wizard, attach certain reports, and then send the completed BAS Wizard file through to us. We perform a quality assurance review on the file, work with you to correct any errors, and then lodge the BAS on behalf of your client.

The Tax Practitioners Board does not prescribe or mandate any specific means by which you need to count or record your hours of relevant experience. The Statement of relevant experience for a BAS Agent, which accompanies your BAS Agent registration application, asks the following questions (with respect to four years preceding your application date):

• Total number of clients
• Total number of activity statements prepared
• Total number of hours undertaking BAS Services

Ultimately, the number of hours you put on the form will need to appear reasonable to the assessing officer at the TPB when viewed in light of the earlier questions regarding number of clients and activity statements.

ABN BAS does not record hours for you. We have no way of knowing how many hours you have spent in the lead-up to submitting a BAS to us (for example, coding tax invoices and transferring data into a software program), nor would we know whether you have validly accrued hours in ways that do not involve us (for example, by working under the supervision and control of another Tax Agent ort BAS Agent).

Thus, best practice would be for you to keep your own record of how you are accruing your hours of relevant experience. ABN has an easy to use Relevant Experience Register for you to record your hours. Although not mandatory, such a record will be useful if you are asked by the TPB at the time of your registration how you arrived at your figure.

There are no “hard and fasts” when answering this question. It will depend on a range of factors including:

1. The number of clients and activity statements you are involved in;
2. The extent of your involvement in each BAS;
3. The level of complexity in each BAS;
4. The level of “hands on” in each BAS (some BAS will be more automated than others);
5. Whether your work patterns are consistent or fluctuate throughout the year;
6. Whether you ultimately require 1000 or 1400 hours of relevant experience (which depends on whether you are a voting member of a registered Tax Agent or BAS Agent Association).

By keeping a record of your hours for a sample period of time, such as three months, you should then be able to get a reasonable sense as to the total length of time needed to accrue your required number of hours.

If you have been using ABN BAS to provide BAS Services to your clients, the work that you perform when completing the BAS Wizard, as well as the work that you perform in the lead-up to the BAS (for example, coding tax invoices and transferring data into a software program) all counts as hours of relevant experience as you will, in effect, have been working under our “supervision and control” in accruing those hours.

When the time comes for you to apply for your BAS Agent registration, ABN BAS can help prepare and “sign off” on the Statement of relevant experience for a BAS Agent, which you will be required to submit to the Tax Practitioner’s Board (TPB).

To obtain a Statement of relevant experience for a BAS Agent, please visit our Supplementary BAS Services page in the Member Centre.

The requirements for renewing a registration are outlined on the Tax Practitioners Board website on the Renewing a BAS Agent registration page. Of the various requirements, there are two in particular where we can assist:

1. You must maintain, or will be able to maintain, professional indemnity (PI) insurance that meets the TPB’s requirements.

2. You must meet continuing professional education (CPE) requirements.

With respect to PI insurance, we are pleased to offer members access to what we believe to be two of the most comprehensive PI Insurance products on the market for bookkeepers. These products are offered by Westcourt and iSure insurance.  For information on the providers’ polices and how to apply, visit our PI Insurance page.

With respect to CPE, an ABN membership assists greatly with meeting the requirements. Broadly speaking, the following ABN content would qualify as appropriate CPE:

• Bookkeepers Knowledge Base
• Bookies Bulletin
• Getting Technical Newsletters
• ABN Coffee Clubs
• ABN Conference
• Pillars of Public Practice
• Webinars

“Simpler BAS” refers to a simplification of GST reporting for eligible small business by reducing the amount of GST information required in business activity statements (BAS).

From 1 July 2017, eligible small businesses will automatically transfer to Simpler BAS. With Simpler BAS, you only need to report the following GST information:

• G1 Total sales
• 1A GST on sales
• 1B GST on purchases
• 1H GST instalments (if you pay by instalments).

The following GST information will no longer be required:

• G2 Export sales
• G3 Other GST-free sales
• G10 Capital purchases
• G11 Non-capital purchases

You are no longer required to complete the GST worksheet.

If your annual GST turnover is less than $10 million, you will be transitioned to Simpler BAS reporting from 1 July 2017.

If your annual GST turnover is $10 million or more, your business is required to report by the full reporting method.

Simpler BAS will not affect how other taxes are reported (e.g. PAYG income tax instalments or PAYG tax withheld), or how often you submit your BAS. You still need to keep records, such as invoices, as proof of any claims you make in your BAS and income tax return lodgements.

Subject to eligibility, small businesses registering from 19 January 2017 have the option to use Simpler BAS immediately.

Each software house will have their own internal roadmaps of how they intend to deal with Simpler BAS and will release their own communications.

It is likely that that each vendor will create a position on the following key matters:

• rationalisation of the tax codes used;
• changes to the interface used when preparing a BAS;
• possible removal of the GST calculation worksheet
• transitioning of tax codes from Full Reporting to Simpler BAS.

In saying that, not all businesses will be eligible for Simpler BAS, so software vendors will need to develop their products in way that can cater for both Simpler BAS and Full Reporting.

ABN BAS will consider, over the course of the September 2017 quarter, what changes, if any, we will make in light of the advent of Simpler BAS.

We also want to observe what changes are being made by the major software houses to their products, before any changes are considered for BAS Wizard.

While simplification as a notion is a good thing, we must balance that against the need to have sufficient information at hand to be able to properly perform our Quality Assurance Review process.

For the time being, there will be no change to either BAS Wizard or the Quality Assurance Review process.