A3.1 The following table identifies ongoing ATO business line activity relating to tax practitioners.

Table A3.1: Overview of existing ATO business line approaches and activities involving tax practitioners
BSL Approach Current (planned) Activities
Aggressive Tax Planning (ATP)

To build the understanding of promoters and advisors of aggressive tax planning and avoidance schemes and take action against those who promote or enable non-compliance.

ATP amalgamation with SNC and PGH may result in some focus changes/shared treatments.

ATP has adopted a risk differentiation matrix approach to provide focus on entities who are potentially promoting tax avoidance:

  • undertake systemic risk and intelligence identification/collection to monitor shifts in lower (low and medium) risk candidates.
  • target marketing and education strategies to deter and deal with medium risk candidates.
  • undertake real time review and audit activity against higher risk candidates.

A suite of services and compliance approaches are available to manage intermediary matters:

  • interpretative advice/taxpayer alerts
  • active compliance case products
  • communication products
  • access to promoter penalty treatment
  • Prosecution

ATP engage with PGH’s Big 4 visit program.


To build an understanding of intermediaries interacting across the Debt risk.

TPALS and Debt combined risk treatment pilot approach (Lodgment and Debt integration)

New action to address ‘agent own’ personal debt management

Multi-tiered engagement/visit program with a range of intermediaries (Big 4, associations, industry representatives, mid-tier practitioners)

Enterprise Solutions and Technology (EST)

To deliver online services and products to tax and superannuation professionals.

Online channel delivery (the ATO Portals, Electronic Lodgment Service, Electronic Commerce Interface, etc)

Indirect Tax (ITX)

Intermediaries are (direct/indirect) participants in the indirect tax system.

ITX operates a Big 4 visit program.

Advice and education for intermediaries dealing with property and excise risk clients.

Limited targeted compliance activity.

Private Groups and High Wealth Individuals (PGH)

To build a strong understanding of intermediaries across populations, industries and risks. Understand what a trusted advisor looks like in the PGH market. Focus on risk transparency and early engagement.

PGH amalgamation with SNC and ATP may result in some focus changes/shared treatments.

PGH undertakes a whole of client engagement approach derived from its intelligence analysis. A new Enterprise Level 2 (EL2) working group is being established to consider a merged PGH (ATP and SNC) intermediary strategy work program.

The ‘Professional Firms’ compliance risk addresses professions adopting complex structures (includes intermediary professions).

PGH operates a Big 4 and professional association visit program.

PGH Risk Managers consider intermediaries as part of their ongoing strategy development. Potential intermediary approach based on lifecycle/behavioural lens rather than a risk based lens under consideration.

Public Groups and International (PGI)

Primarily dealing with public groups and those with international dealings rather than through their registered agents. The use of in-house and 'buy in' advisors to manage specific issues and events is widespread.

PGI operates a Big 4 visit program.

Small Business / Individual Taxpayers (SBIT)

To build the understanding and compliance of registered tax agents dealing with individual taxpayers and take action against those who promote or enable non-compliance.

SBIT has over a number of years developed and operated a four tier compliance treatment approach for agents with individuals clients:

  • Tier 4 (Lowest risk): educational visits with a focus on regional areas.
  • Tier 3: agent review to understand business practices and identify ways to mitigate higher cost compliance intervention.
  • Tier 2: low volume compliance audits resulting from Tier 3 escalation or referrals.
  • Tier 1 (Highest risk): intensive audit action with further internal (Serious Non-Compliance) or external (Tax Practitioners Board) referral.

In addition, SBIT provide a range of compliance and support treatments:

  • Help and educate.
  • webinars, speakers and seminars.
  • Tax Time communication (co-design).
  • Income Tax Refund Integrity review processes (off lining).

A future focus area will address:

  • Online security and identity protection.
  • Offshoring/outsourcing and information security.
Service Delivery

To deliver services to tax and superannuation professionals.

Manage inbound telephony channels (premium practitioner queues and complaints call handling)

  • Around 13% of Customer Service and Solutions (CS&S) inbound call volume (~1.2 million calls) are practitioner initiated.
Serious Non-Compliance (SNC)

To build the understanding of tax crime risk. Intermediaries are (direct/indirect) participants in the tax crime risk.

SNC amalgamation with PGH and ATP may result in some focus changes/shared treatments.

SNC delivers a range of communication approaches through multi channels including governance visits to key intermediaries.

SNC provides administrative prosecution service on behalf of ATO for summary offences (generally following internal referral)

SNC is the gatekeeper for referral for criminal sanction for indictable offences.


To build the understanding and compliance of self-managed super fund (SMSF) tax agent and SMSF Auditor community, and take action against those who promote or enable non-compliance.

Super strategies affecting agents:

  • 1 Illegal Early Release (IER) promoter case
  • Up to 10 tax agent cases where data / Intel identified high risk behaviour
  • 150 approved SMSF auditor cases (many also agents)
  • Trial of 10 cases where it appears agents are misusing approved SMSF auditor details

Superannuation is considering their approach to agents. Potential future strategies are:

  • Excess contributions caps where an agent is involved
  • Leveraging trustee compliance by treating agents who have many high risk clients
  • SMSF agent and SMSF Auditor targeted mail outs as well as audits and reviews
Tax Practitioner and Lodgment Strategy (TPALS)

To build the understanding of registered tax and BAS agents (and other intermediaries) and take action against those who promote or enable non-compliance.

Provide a range of services and compliance/support treatments on behalf of ATO and TPALS including:

  • Practitioner communications
  • Forums and consultation (ATPAG, BASAG)
  • Tax Practitioner Board Gatekeeper
  • Tax Practitioner Services (contact centre - role transitioning to Client Account Services)
  • Lodgment Program Framework including associated treatment matrix (deferrals, lodgment assistance)
  • Systems support and maintenance (communicating and liaising on Portal/channel outages)
  • Higher Risk Agent Program
  • Key Agents Program
  • Agent induction
  • Support and assistance program
  • Incident management
  • ELS to SBR transition project
  • Professional to Professional (tax agent and legal professionals)

Source: ATO, Intermediaries approach - Blueprint outlining our approach to management of intermediary engagement, compliance and support (June 2014), pp 21-24.