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BAS & Bookkeeping Services – Aren’t They the Same Thing?

If you want to be a bookkeeper in today’s environment and abide by the Tax Agent Services Act 2009, you will need to ask yourself a question: What sorts of services do I want to provide to my clients?

If the answer includes:

  • Preparing and/or lodging a form that relates to your client’s taxpaying liabilities, obligations or entitlements e.g. Business Activity Statement, Instalment Activity Statement or Payment Summaries
  • Giving your client advice about a BAS Provision that he relies upon to exercise his taxation obligations. A BAS Provision includes – GST Law |Wine Equalisation Tax Law | Luxury Car Tax Law |Fuel Tax Law |Fringe Benefits Tax Law |PAYG (Pay As You Go) Withholding | PAYG Instalments
  • Calling the ATO on behalf of your client in relation to a BAS Provision.
  • Interpreting or applying a BAS Provision in the course of completing client work
  • Installing software like MYOB or QuickBooks (now known as Accounts) and setting up the GST codes in the Chart of Accounts for a client
  • Coding tax invoices and then entering this information onto a client’s accounting system
  • Reconciling data relating to a BAS Provision (see above) so that you can determine the figures that need to be added to a client’s Activity Statement
  • Completing an Activity Statement on behalf of a client or instructing the client about which figures he needs to include
  • Determining the withholding obligations for a client’s employees. This also includes preparing the employees’ Payment Summaries

then you are providing BAS services and you will need to register with the Tax Practitioners Board to be a BAS Agent. It is illegal to provide BAS services for a fee without being registered! You can no longer offer these services to your clients if you do not want to register as a BAS Agent.

If, however, your answer is:

  • Data Entry
  • Bank Reconciliations
  • Processing Payments
  • Record Keeping
  • General Reporting e.g. draft Profit and Loss, draft Balance Sheet, draft Trial Balance etc.
  • Coding Transactions to the accounts based on instructions provided by the client.

then you are providing general bookkeeping services and you will not need to register as a BAS Agent. You may also work under the guidance of another BAS Agent or Tax Agent and you will be seen to be working legally without actually having to register as a BAS Agent yourself. Note too that if you are employed by a company (not a contractor arrangement) to complete BAS work or tasks, then you do not have to register as a BAS Agent.

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10 thoughts on “BAS & Bookkeeping Services – Aren’t They the Same Thing?”

  1. Marian Mouttet

    Dear Louise,

    Thank you for the above article. It really clarified the matter for me as I am a bit concerned that I cannot register as a BAS Agent due to not having the required current hours or a qualificaqtion. It is nice to know that I can call my services General Bookkeeping Services and still provide them.


  2. Dear Louise,

    I’ve only just came across your blog on 1st July 2022 (a few years after you wrote it) on this topic in relation to BAS Services & Bookkeeping Services – if a client/potential client is using a manual bookkeeping system (eg: Excel spreadsheet, an account book/cash receipts and cash payments book) for keeping a record of their income and expenses – would entering/writing in any of these transactions under a ledger category (eg: customer payments, materials, rent, petrol etc..) still be considered general bookkeeping services under data entry or still a BAS Service?

    Also in relation to installing accounting software and setting up GST codes – is that still considered providing a BAS Service if you just leave the codes that were set up already in the software (default codes) as they are ie: you don’t edit any of the accounts (like changing an account name) in the Chart of Account nor add any new account codes?
    Thank you.
    Kind regards,

    1. Hi Robyn. Thanks for reaching out with your questions. The main thing to remember in this case is what is the scenario under which you are entering data? If you are simply entering figures into a spreadsheet that has been prepared by the client or tax agent, and you do not alter it in any way, then this is bookkeeping. If, however, you are creating the spreadsheet and formulas to bring about a result that affects the client’s tax position, then that is a BAS Agent service. The same with the tax code question. If you do not change the tax codes at all when entering transactions i.e. make decisions as to whether expenses/sales include or don’t include GST, then that is bookkeeping. If, however, you change the codes to suit particular expense/sale situations, then that is a BAS Agent Service. In short, as long as you do not make any changes to the system the client or tax agent has given you when entering data, then what you are doing is bookkeeping, not producing BAS services. As long as you have it in writing in your letter of engagement as to what it is you are doing (and what you are not doing), then you should be fine. Does that help?

      1. Hi Louise,
        Thank you very much for your reply and yes it is does help especially the scenarios you gave to show the difference of when a task is bookkeeping and when it is a BAS Agent service. I may have a potential client (very small service business) where so far from what I know it will be more a bookkeeping service I would provide if all goes ahead (I would just need to make clear that I have to not go near/make decisions regarding his BAS/tax position otherwise I would be going into BAS Agent service territory which I’m not allowed to do) he’ll probably only need me entering his data a few hours per month as I’ll only be doing this in addition to working at my part-tme job where I’m employed at a business doing the bookkkeeping – I’m not taking on any other clients, unless I decide to go into business for myself once I’ve completed my accounting qualifications and satisfied the TPB requirements to register as a BAS Agent – I’m 99% sure at this point in time he will generate his invoices himself (instead of me doing for him) and I’ll be entering in his income and expenses (and in which I would be able to see on any invoices/shop receipts that GST has either been charged on the purchases or not)….Robyn

        1. Hi Robyn, I’m glad I was able to help. It sounds like you’re on the right track there. Good luck with the new client should he eventuate, and good luck too, with your studies!

  3. Thankyou Louise and Robyn for your conversation.
    I am also looking at doing some basic data entry remotely as a business and have been left very confused as to whether I can legally perform the tasks mentioned in the article as General bookkeeping services.
    I am trying to find the relevant wording in the Tax Agent Services Regulations 2022 legislation to confirm it, however I am struggling to find it.
    I appreciate the advice on Letter of engagement.

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