Further to the 30 March 2021 submission by Chartered Accountants Australia and New Zealand (CA ANZ), CPA Australia, the Business Law Section of the Law Council of Australia and The Tax Institute (the Joint Bodies), CA ANZ has consulted with its members and has provided additional comments in a separate submission.

The key points raised by Chartered Accountants CAs and CA ANZ member firms relate to:

• The singling out of professionals for special ATO treatment vis-à-vis other individuals in business who also utilise legitimate business structures
• Out-dated and incorrect notions of personal services income
• The lack of a “safe harbour” 
• High tax compliance costs imposed on Individual Professional Practitioners and (in reality) their firms.

CA ANZ seeks further opportunities to work with the ATO on drafting this guidance.