The Joint bodies have lodged a joint submission with Treasury on Implementation of the Government's response to the Review of the Tax Practitioners Board (TPB). The Joint bodies are the external professional body members of the Tax Practitioners Governance and Standards Forum (TPGSF).

Some key points in the submission include:

• We welcome the introduction of a prohibition scheme for disqualified entities but hold concerns about certain aspects, especially the notification scheme for practitioners. Therefore, we question whether the measure should be delayed and considered further. 
• We reiterate our objections to the Minister having the power to elaborate on or supplement the Code of Professional Conduct (the Code), 
• We reiterate our concerns about the inclusion of the concept of “tax system integrity” in the Object of the TASA. 
• As the proposed change to the renewal process will still allow the Board to grant renewal terms of longer than one year, we recommend a staged implementation supported by new systems that minimise the disruption and reduce the burden on practitioners. 
• We support the establishment of the TPB Special Account on the condition that there will be no increase in TPB fees.

We note that the Review recommendation related to sanctions also requires consultation as a matter of priority, including adjustments to section 50-25 civil penalty provision.

In addition, effective implementation of the proposed changes requires the TPB to administer the disqualified entities regime, improve the public register, streamline renewal processes, and modify its governance. The Government should ensure that the TPB is properly funded to adopt these changes.