Chartered Accountants Australia and New Zealand (CA ANZ) has lodged a submission in response to the Australian Taxation Office’s (ATO) Draft Vulnerability Framework (the Framework). The submission supports the ATO’s efforts to create a more inclusive and empathetic tax system and offers constructive feedback to strengthen the Framework’s clarity and effectiveness.

The submission raises the following key points.

1. Recognition of Tax Agents as Partners

CA ANZ recommends that the Framework explicitly acknowledge the role of tax agents and professional advisers. These professionals are often the first point of contact for vulnerable individuals and small businesses, and their contribution to identifying and supporting clients should be formally recognised.

2. Broader Definition of Vulnerability

The submission calls for an expanded definition of “vulnerable taxpayers” to include small businesses and self-managed superannuation funds (SMSFs), recognising that these groups also face significant challenges in meeting tax obligations.

3. Next steps

CA ANZ suggests the ATO consider the Australian Financial Security Authority’s (AFSA) Vulnerability Framework as a reference for the next phase of implementation. To ensure the Framework is effective and inclusive, the ATO should ensure that processes to deal with vulnerable circumstances are co-designed with people with lived experiences. 

CA ANZ’s Aboriginal and Torres Strait Islander Panel has also raised concerns about current ATO debt collection practices which conflict with the principles of the Framework. CA ANZ urges the ATO to prioritise these issues in the next phase of development.