23/03/2006
GST for BAS Preparation accreditation
Guided by tax agent
The Institute of Certified Bookkeepers aims to establish structure and certainty to the bookkeeper industry, bringing recognition to bookkeepers for the work they do and how well they do it.
The ICB believe that bookkeepers are an integral part of the business processes that lead to businesses preparing its Business Activity Statement (BAS), however not all bookkeepers want to be accredited to liase with the tax office on behalf of clients. Some certainly are very involved in the preparation of busines information that are directly involved in the preparation of business information that directly influences the BAS. Government is seeking to clarify and prescribe who is permitted to do any work that relates to the declaration of numbers on the BAS.
Much bookkeeping work involves applying GST advice provided by the responsible accountant or business owner. The ICB do not believe this "application" of GST advice needs to be subject to the same restrictive regulations that should apply where the subcontract bookkeeper is reviewing data entry and interpreting business reports as part of the process begins by the qualified accountant or tax agent interpreting GST law and BAS requirements for the particular business. The bookkeeper uses that advice to process the transactions. Section 25L and the associated regulations relate to the review of business information to prepare the BAS.
Under law, the ATO allows a bookkeeper to prepare the BAS as long as they are working under the guidance of a tax agent (in relation to that particular BAS). The ATO legal position and explanation of these requirements can be found at:
http://ATO.gov.au/print.asp?doc=/content/68591.htm
The program is designed to assist the bookkeeper to do their work and to meet those requirements. The ATO guidelines indicate significant responsibilty on the guiding tax agent.
The Program
In order to provide bookkeepers with the legal ability to prepare the BAS, the ICB will provide an Education, Assessment and Review program for its member bookkeepers, enabling the preparation of a client's BAS by those members utilising the ATO guidelines in relation to Section 251L, specifically related to “working under the direction of a registered tax agent”.
This system is designed in response to the government's legal requirements imposed on bookkeepers. It is not the ICB's requirements (i.e. don't shoot the messenger). It is designed as an effective means for bookkeepers to remain legal in the work that they perform on a daily basis.
The purpose of this program is to provide assistance to businesses, their bookkeepers and their accountants in efficiently and effectively preparing the BAS.
ICB note that the ATO guidelines require that the tax agents providing the review must have a relationship with the taxpayer and not just the bookkeeper, hence the additonal communication and interaction is required
The program is specifically designed for self employed and subcontract bookkeepers who wish to prepare the BAS on behalf of their clients. Other bookkeepers may use features of the program.
ICB will resource an appropriate panel of registered tax agents to provide the overview and expert assistance required.
Bookkeepers who wish to make use of this program must:
1) be full current members of the ICB; i.e. Members (“MICB”) or Fellows (“FICB”)
2) hold a current ICB Certificate of Public Practice
3) undertake the ICB GST for BAS preparation training
4) successfully complete the assessment for “ICB Certificate of GST for BAS Preparation”
5) separately register for the BAS preparation program and agree to the terms and conditions
6) register each client and each entity whose BAS is to be prepared in accordance with this program
7) provide signed consent of the client in relation to their BAS being prepared in accordance with this program
8) submit the client's datafile (or information) for review - by the panel of tax agents - as often as is determined by the panel
9) respond and take action to any queries or directions as a result of the review.
HOW WILL IT WORK
Following registration with the ICB BAS preparation program, the client's file will need to be submitted for review. The administrator password must be supplied. An analysis will be performed, and a report/enquiry back to the bookkeeper as required. When the review and clarification process is completed, a final report will be provided to both the bookkeeper and the client.
On a monthly or quarterly basis, the bookkeeper works with the client’s information and reconciles the files as required, following and completing the ICB checklist for BAS preparation procedures. The bookkeeper should also note other matters that may have been raised in previous reviews. Once the bookkeeper is happy with the file and the information, they would then proceed to prepare the BAS. The client must still sign the BAS.
Based on the initial review and the stated requirement for each client, the file may need to be submitted for further review for each BAS.
The bookkeeper MUST refer any GST or BAS preparation queries to the tax agent panel and MUST NOT estimate the GST or BAS position for a client. It is the responsibility of the bookkeeper to raise any matters they believe requires specific review.
COST
Proposed cost structure (subject to confirmation)
Normal Price ICB Members
GST for BAS Preparation Training N/Avail* $150
GST for BAS Assessment & Certification N/Avail* $75
Initial review and report process following registration of client $700 $100
Fee for each BAS review $150 $40
*The ICB Training and Assessment is not available for non ICB Members.
This program is scheduled for release on the 30th June 2006.
CONFIDENTIALITY
The client's information is subject to the same privileges of confidentiality that apply to registered tax agents and accountants. The client's files will not be retained by the tax agents, however the reports produced (as a result of the review) will be retained. It is a condition of participation in this program that the bookkeeper and the client will ensure a backup of the submitted file is maintained for 7 years.
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