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Law Council of Australia

Business Law Section

Transition to strengthening client verification

The submission to the Australian Taxation Office in response to the Consultation Paper entitled “Transition to strengthen client verification” (the draft guidelines) was prepared by the Taxation Committee of the Business Law Section. 

The Taxation Committee recognises the problems associated with identity theft and fraud and that steps that prevent access to material that would make identity theft and fraud easier ought to be taken. The committee is concerned that the draft guidelines do not clearly identify to whom the standards will apply once they become compulsory.

While the content of the draft guidelines suggests they are limited to tax professionals who have direct interface with Australian Taxation Office (ATO) systems, namely registered tax and BAS agents, the draft guidelines use the terms “tax profession” and “tax practitioners” without defining these terms. To the extent that there is a “tax profession”, that profession is made up of accountants, registered tax agents, registered BAS agents, academics, people in government working in the taxation field and lawyers.

You can read the full submission below.


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