Intermediaries play an important role in helping people meet their tax obligations and access their social policy entitlements. The proposals aim to remove barriers to the development of different intermediary business models. The paper also seeks feedback on allowing intermediaries to provide services that would enable them to calculate income tax and make payments throughout the year on behalf of their customers.

CA ANZ’s key submissions are:

• Further work should be undertaken to develop a principles-based framework to set the vision and guide the future direction of changes in tax administration. 
• Absent from the proposals is the fundamental principle that the Inland Revenue computer system, (START) should enable and support an efficient and effective tax administration system, recognising that this would involve future changes and/or enhancements to functions in START.
• It is critical to ensure the rules for intermediaries are incorporated into and align with Inland Revenue’s workstreams on the digital ecosystem and the impact of artificial intelligence (AI). In our view, the three projects – intermediaries, the digital ecosystem and AI – are inter-related and should not be considered in isolation. 
• The proposals in the issues paper to introduce new categories of intermediaries and to amend existing rules for others (for example, tax representatives, tax agents) are better viewed as an interim measure. In the case of the proposals to introduce the concept of a tax crediting agent, they should not proceed. 
• Further thinking is required to ensure that the proposals are workable, coherent (within each category or area and in relation to other workstreams such as the digital ecosystem and AI), neutral, and fit for the future.