A BAS Agents approach to clients  - What should your obligations be?

As bookkeepers attempt to grapple with what it might mean to be a registered BAS Agent (aswell as being a professional competent bookkeeper) various conversation topics are raised:

"but we have to sight all the TAX invoices otherwise we can’t prepare the BAS  (refer discussion last newsletter)

"I have to check past periods BAS to ensure nothing has changed

"a client d"s not know the range of responsibilities of what is required to be done by the bookkeeper

So what are the obligations upon a professional in dealing with a client? 

Especially when there becomes a legal obligation upon that professional

Especially when another professional (in our case an accountant) may end up reviewing or seeing our work.

ANSWER

It is an absolute obligation on the professional to have a comprehensive discussion with the new or existing client about what the professional is being engaged to consult on, or what work they are being engaged to perform.

Document that understanding in an engagement letter.

Likewise it is important for that professional to ensure the client also understands what the professional is not being engaged to do.

A future BAS Agent may hold a full BAS Agent registration and therefore in theory is able to be relied upon by the client for the entire range of BAS services: ascertaining, advising, liaising and representing the taxpayer in relation to all BAS Provisions.

However if the client is not willing to or possibly not able to pay the BAS Agent for all services IT REMAINS correct and likely that you can and should be engaged for a limited scope of services.  ie you can’t do everything if the client can’t pay you to do so.

What is important is to ensure that you have documented and understood between yourself and the client at the start and again from time to time what your range of services are and are not.

If you have not been asked to sight all tax invoices nor to check that they have them - then don’t spend the time to do so.   You may not be paid for it.  What is important is to ensure that the client knows they have an obligation to have the tax invoices in their possession that they must be of the right form and inform them that you have not checked.

A registered BAS Agent that is doing any work for a client must ensure that they have stated the work they have done.  To be absolutely clear you could then state the potentially enormous list of all the things you haven’t done, (however it probably isn’t appropriate marketing).

PRACTICAL IMPLEMENTATION

A professional will let a client know everything that the client should be doing in order to comply and to have effective books and records. (in writing)

A professional will agree with a client what services the professional is being engaged to perform (in writing)

A professional will not process something to an incorrect account but may place items in suspense accounts if they need further information of work done before the correct posting can occur.

A professional will document and inform the client, and potentially, the accountant of that client, in writing of decisions made in processing that should be highlighted and potentially warrant review.

WHAT IF the Client says "just do this BAS and I can only pay for 2 hours at our agreed $88 per hour

A quick review and scoping of how much can be achieved in that time should be conducted.

Let the client know what will be achieved and what degree of reliance the client should place on the outcome.

Let them know that further work is required and an estimate of what it would cost them to have that work done.

Confirm the date range of the transactions you have considered and therefore that you haven’t reviewed outside those dates.

If you find errors that require time to fix - list them, document them but don’t spend the time to fix them unless specifically and additionally agreed to by the client.

Ensure that when you provide the information to the accountant that the range of work that you consider is still required to be done is noted.  Also provide the reports that show what has been done so they are not repeating your work.

Summary

It is your responsibility to agree with the client what you are being paid to do.

It is your responsibility to notify the client of their legal obligations.

It is NOT your responsibility to adopt all the clients’ legal obligations as your own.

It is your responsibility to comply with the law therefore you must not process or prepare forms that you know is in contravention of the law.

This article can be found in the October 2009 ICB Newsletter - click here to view that newsletter

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