Anyone can call themselves a bookkeeper. To charge you for working out or lodging your BAS, someone has to be registered with the Tax Practitioners Board as a BAS agent or a tax agent. To charge you for your income tax return, they have to be a tax agent.
We think a venue is better off with one registered tax agent doing both than with a bookkeeper, a BAS agent and an accountant each holding part of the file. Your ATO debts can sit in two accounts, and splitting the work means two firms talking to the ATO about one venue.
Without registration, a bookkeeper can do the data work
The TPB’s BAS services page sorts the jobs. These are not BAS services, so anyone can charge you for them:
- Bank reconciliations
- Entering data, as long as they are not working out the figures for your activity statement
- Coding invoices under the instruction and supervision of a registered tax or BAS agent
These are BAS services, and need registration:
- Setting up GST and other tax codes in your accounting software, tailored to your business
- Coding transactions where the GST rules have to be applied
- Working out, completing or confirming the figures on your activity statement
In a venue, watch the GST codes in Xero. Setting them up for your menu and your suppliers is applying the GST law to your business, which is why it needs registration.
A fee still counts when the BAS work is bundled with other services. The exception is your own staff. The TPB’s rules on a fee or other reward exclude employees working for their employer on a wage, so an in-house bookkeeper on your payroll can prepare your BAS without registering.
A BAS agent covers GST, PAYG withholding, STP and super
For a venue, the BAS provisions that matter are the GST law and the PAYG system. On the payroll side, the TPB lists these as BAS services:
- Working out PAYG withholding for your staff, including on leave payments
- Running payroll that applies the tax rules, including setting up or reporting through STP
- Super guarantee work tied to payroll
- Working out a super guarantee charge and lodging the SGC statement
We have lodged SGC statements for venues that came to us with super paid late or not at all. The rules for paying super changed on 1 July, and our payday super article covers them.
A BAS agent can also deal with the ATO for you on these, including payment plans on tax debts, but their authority is limited to dealings about BAS provisions. Lodging a quarterly BAS through a registered agent may also get you extra time, except for the October to December quarter, which already has a one-month extension.
A tax agent adds your tax return and all your ATO accounts
A tax agent can do everything above unless a condition on their registration limits them, because a tax agent service covers any tax law and BAS services sit inside it. This work falls outside a BAS service and may need a tax agent:
- Preparing or lodging income tax returns
- Advice on salary sacrifice and salary packaging
- Advice on how fringe benefits tax applies
- Advice on claiming a tax deduction for super contributions
A tax agent can also object to an assessment for you, and has authority to access all roles on your ATO accounts.
Two ATO accounts means two payment plans
The ATO needs separate payment plans for your income tax account and your activity statement account. Take a venue doing $20,000 a week that comes out of winter behind:
- Activity statement account, for GST and PAYG withholding: $15,000
- Income tax account: $5,000
- Total owing: $20,000, on two payment plans
A BAS agent can ask for a plan on the $15,000. A tax agent can act on both. We also find ATO debt parked in a file and forgotten about, and it is easier to catch when one agent can see every account.
Check the register before anyone touches your BAS
Search the name, business name or registration number on the TPB register. The record shows whether they are a tax agent or a BAS agent, their status and expiry date, and any conditions or sanctions. A registered practitioner doesn’t need your myGov password to act for you, so don’t give it to anyone who asks.
If someone unregistered lodges late, or lodges a wrong BAS that leaves a tax shortfall, the ATO may impose penalties on you. With a registered agent, the ATO’s safe harbour can protect you from some of those penalties, as long as you gave them all the relevant information. With an unregistered preparer you have no safe harbour.
The preparer is exposed too. The TPB can ask the Federal Court for civil penalties, and since 1 October 2026 the Tax Agent Services Act makes charging for BAS services while unregistered a criminal offence.
What we would do
- Look up anyone who touches your BAS or payroll on the TPB register
- Match the registration to the work: a BAS or tax agent for BAS, IAS, STP and super, a tax agent for the return
- Keep both ATO accounts with one registered tax agent if you can
Roger is a registered tax agent. Essentials covers your monthly IAS and quarterly BAS, and Foundation adds your tax returns.