Tax Practice Compliance

Tax agent record-keeping requirements: a practical guide for Australian practitioners

Australian registered tax practitioners must keep records that correctly record the tax agent services they provide to clients, including services provided on their behalf.

The requirements go beyond simply retaining a copy of the lodged return.

Under section 30 of the Tax Agent Services (Code of Professional Conduct) Determination 2024, the records need to capture the service provided, information considered, relevant client and practitioner advice and, for more complex matters, the facts, assumptions and reasoning supporting the advice.

For many accounting firms, that makes the quality of the workpapers, file notes and review record increasingly important.

Published 27 August 2026. Last reviewed 27 August 2026. Technically reviewed by the Taxpartna tax team.

This guide explains the requirements from the perspective of the tax file.

At a glance: a good tax file should make it possible for another appropriately qualified person to understand what service was provided, what information was considered, how important issues were dealt with and what outcome was reached.

This is general information only and is not legal or tax advice. Practitioners should refer to the current Tax Practitioners Board guidance and legislation for the precise requirements.

What are the TPB record-keeping requirements for tax agents?

The relevant requirements are contained in section 30 of the Tax Agent Services (Code of Professional Conduct) Determination 2024.

The TPB's current guidance explains that registered tax practitioners must keep records that correctly record tax agent services provided personally or on their behalf.

In broad terms, the records must:

be in English, or readily accessible and easily convertible into English
generally be retained for at least five years after the tax agent service is completed
show the nature, scope and outcome of the service
reference information reasonably considered when providing the service
include relevant advice received from the client
include advice provided to the client
for more complex matters, record relevant facts, assumptions and reasoning supporting the advice, including the basis and methodology used for relevant calculations, estimates or determinations

These requirements now apply across the registered tax practitioner population following the transitional application dates that applied during 2025.

The important practical point is that a completed return by itself may not explain the work that sat behind it.

What should a client tax file show?

There is no requirement that every accounting firm use the same workpaper template or document-management system.

The test is more substantive: does the retained record correctly record the tax agent service?

A practical way to think about the requirement is:

Area	What a useful tax file could show
Nature of service	What the practitioner was engaged to do
Scope	What was included, excluded or separately advised on
Information considered	Workpapers, financial statements, client records, correspondence and external advice
Client instructions	Relevant factual information and instructions received
Outcome	Return, advice, calculation, application or other completed service
Advice provided	Material advice communicated to the client
Complex matters	Relevant facts, assumptions, technical reasoning and methodology
Review	Material questions, evidence obtained, corrections and conclusions

The right-hand column is a practical illustration, not a mandatory TPB template.

Different engagements will justify different levels of documentation.

A straightforward individual return will not necessarily require the same record as a complex trust restructure or Division 7A matter.

Are tax workpapers part of the required records?

They can be.

The TPB specifically recognises working papers as an example of records relevant to recording tax agent services.

Workpapers are often where the firm records:

calculations
reconciliations
assumptions
source information
tax adjustments
technical positions
links between the financial accounts and return

But the existence of a workpaper does not automatically mean the overall client record is complete.

Consider a company tax file where the financial statements show one related-party loan balance, the tax workpaper shows another amount and the final income tax return contains a third.

The firm may have retained all three documents, but a future reviewer still needs to understand:

which amount was accepted
why
what evidence was considered
whether the discrepancy was resolved
what was ultimately lodged

That is where review notes and file-note evidence can become important.

A record should explain more than the final number

A recurring problem in tax files is that the final figure may be correct while the pathway to that figure is difficult to reconstruct later.

For example:

Taxable income: $482,400

may tell a future reviewer very little by itself.

A stronger file might also show:

the accounting profit used as the starting point
permanent and temporary tax adjustments
supporting schedules
unusual items investigated
information obtained from the client
treatment of material judgement areas
how the final tax reconciliation connects to the lodged return

Good documentation does not mean creating paperwork for its own sake.

The goal is to leave enough evidence to understand the service and important decisions without having to recreate the entire job from the beginning.

How long must tax agents keep records?

Section 30 requires relevant practitioner records to be retained for at least five years after the tax agent service has been provided.

The TPB considers the service to have been provided when it is completed.

That date may not always be the same as:

the end of the income year
the date the client first supplied information
the date work commenced

Tax practitioners should also distinguish their own obligations from separate record-keeping requirements that taxation laws impose on clients.

The fact that the firm retains a document does not necessarily remove the client's own legal obligation to retain records.

Likewise, a client's obligation to retain a record does not necessarily mean the practitioner can discard information required to correctly record the tax agent service.

Can records be electronic?

Yes.

The TPB's guidance allows records to be retained electronically, provided they satisfy the applicable requirements.

Electronic records should be readily accessible and retrievable.

Accounting practices should also consider:

information security
confidentiality
document integrity
access controls
backups
retention policies
the ability to retrieve old client records when required

For firms moving between practice-management systems, workpaper products and document-management platforms, this is particularly important.

A theoretically retained document is not much use if nobody can retrieve it when the file is reviewed several years later.

What about work performed by staff, contractors or offshore teams?

The section 30 obligation is not limited to work physically completed by the registered practitioner.

It also covers tax agent services provided on the practitioner's behalf.

Depending on the arrangement, that can include services provided through:

employees
contractors
outsourced teams
offshore personnel
remote supervisory arrangements

The firm therefore needs processes that result in adequate records being created and retained across the whole workflow.

This matters where preparation is decentralised.

If a preparer completes work offshore, a manager reviews it in Australia and a registered practitioner signs the return, the retained file should still make sense as a coherent record of the service. See offshoring tax work: TPB requirements.

What should a tax review leave behind?

A completed tax review should not vanish when the reviewer closes the job.

Depending on the nature and complexity of the engagement, useful review evidence may include:

who performed the review
what documents were considered
significant values checked
cross-document inconsistencies identified
questions raised
responses received
additional evidence obtained
adjustments made
technical matters escalated
unresolved items
final reviewer conclusion
sign-off date

Not every field is a legislated requirement.

The practical question is whether the retained record adequately explains the work performed and significant decisions made.

Practical tax-practice record-keeping checklist

Before closing a tax job, consider whether the file contains enough information to answer the following questions.

Engagement and scope

Is the client and relevant entity clearly identified?
Is the nature of the tax agent service clear?
Is the scope of the work understandable?
Are material limitations or exclusions recorded where relevant?

Information and evidence

Can the important figures be traced to workpapers or supporting information?
Is significant client advice or instruction retained?
Is relevant third-party advice retained where relied upon?
Are important assumptions identifiable?
Is missing information or reconstructed information explained?

Technical matters

Are complex or judgement-heavy treatments adequately supported?
Is the basis of significant calculations, estimates or determinations understandable?
Are significant departures from prior-year treatment explained?

Review

Are material review issues recorded?
Are questions and responses retained where relevant?
Can the reviewer see whether an issue was resolved?
Is the final outcome apparent?

Retention

Can the records be readily retrieved?
Are electronic records protected from inappropriate alteration or access?
Will the firm's retention system preserve the required records for the applicable period?

Record keeping and quality assurance are connected

Record keeping and tax quality assurance are not the same obligation, but the two processes naturally overlap.

A useful review process creates information that can improve the final client record.

For example, if a reviewer identifies that a dividend figure differs between the financial statements, tax workpapers and return, resolving the issue produces valuable evidence:

1what was inconsistent
2where each amount appeared
3what source was checked
4what correction was made
5what amount was ultimately accepted
6who reviewed the resolution

That is much more informative than a generic review note saying "Checked - OK."

For a practical framework, see Taxpartna's tax review file note checklist.

Where Taxpartna fits

Taxpartna is designed as an additional quality-assurance layer over the completed tax file.

It reads the submitted workpapers and supporting documents, compares information across the file and gives the firm's reviewer a structured view of the results.

The completed review can capture items such as checks performed, figures considered, source documents, explanations, matters requiring attention and reviewer sign-off, and can be exported for retention in the client file.

Taxpartna does not determine whether a practitioner's records satisfy section 30 and does not replace the firm's own record-keeping policies or professional judgement.

Its role is to help make the review of the completed file more systematic and easier to evidence.

See how Taxpartna reviews a completed tax file See the review workflow

Related resources

Primary sources

Important information. This guide is general information only and is intended to support professional review. It does not replace the Tax Agent Services Act, the Code of Professional Conduct, current TPB guidance or the registered tax practitioner's judgement. Taxpartna is a quality assurance assistance platform and does not provide tax advice, prepare returns or give final sign-off.