Yes, someone in the Philippines can do the work of putting a business activity statement together: the coding, the reconciling, the chasing, the workpaper. What cannot move offshore is the judgement about how something is treated, and the lodgement itself, both of which sit with your registered agent when the statement belongs to a client; supervising the preparer does not change that. If it is your own business's statement, an authorised person inside the business reviews and lodges it. Either way you stay responsible for what the offshore preparer produces, so the checking has to be real and you have to be able to show it.
Yes, the preparation can. The lodgement cannot, and neither can the advice, because both are BAS services under the Tax Agent Services Act 2009 and registration with the Tax Practitioners Board attaches to the registered agent, not to the process.
That is the short answer. Everything difficult about it lives inside two words, "preparation" and "supervision". This post is about where the Act draws that line and what it asks of you once you have crossed it. If you want the operational version, how to structure the quarter and what a reconciliation pack should contain, that sits in our guide to handing over BAS prep.
This is general information, not legal or financial advice. Confirm anything you intend to act on with your own registered agent, professional association or adviser.
What the Act actually regulates
Section 90-10 of the Tax Agent Services Act 2009 defines a BAS service as one that relates to ascertaining or advising about an entity's liabilities, obligations or entitlements under a BAS provision, or representing that entity in its dealings with the Commissioner, provided in circumstances where the entity can reasonably be expected to rely on it. Section 50-5 makes it a civil penalty to provide such a service for a fee or other reward while unregistered.
Read the definition slowly, because it is narrower than most people assume. It regulates ascertaining, advising and representing. It says nothing about reconciling, coding to a rule someone else has already written down, chasing a missing invoice or assembling a workpaper.
So the test for any task is not how technical it looks. It is whether the person doing it has to decide something. Coding a supply to the GST treatment your firm has already recorded against that client is preparation. Deciding whether the supply is GST-free is a BAS service. Same transaction, two different jobs, and the whole difference is who forms the position.
The equivalent line in every other regulated profession is mapped in what you legally cannot delegate offshore. For BAS work the practical version is short: the work up to the judgement travels, and the judgement does not.
Supervision and control is not the same as a signature
Code item 7 of the Code of Professional Conduct, in section 30-10 of the Act, requires you to ensure that tax agent services you provide, or that are provided on your behalf, are provided competently. The TPB's factsheet on outsourcing and offshoring states that this includes services provided by an unregistered external contractor, in Australia or abroad. The obligation follows the work overseas. It does not stop at the border.
What that means in practice is the subject of TPB(GS) 53/2024, the Board's guidance on supervision and control. Glancing at a document to see whether the contents look reasonable does not get you there. The Board's own phrase is that there must be "substantial supervision".
The useful way to think about this is evidentiary. If the TPB asked you next month what supervision you exercised over last quarter's activity statements, could you produce anything? A review checklist with a name and a date on it. A query list showing what was escalated and how it was answered. A coding manual the preparer worked to. If the honest answer is that you looked at it and it seemed right, you have a Code item 7 problem regardless of where the preparer sits.
Supervision also will not do the one thing people quietly hope it will do. It cannot make an unregistered person's regulated act lawful. Registration is personal to the holder. You cannot supervise it into existence, in Manila or in the next room.
Consent comes before the file moves, not after
This is the step firms miss most often, and it is the cheapest one to get right.
Code item 6 says that unless you have a legal duty to do so, you must not disclose client information to a third party without the client's consent. The TPB's factsheet defines a third party as any entity other than the client and the tax practitioner, and says explicitly that it can include outsourced entities. An offshore team member working inside your clients' ledgers is a third party.
Consent has to exist before the disclosure. One obtained in March does nothing for a file that moved in February. The usual way to handle it is a clause in the engagement letter, which TPB(GS) 31/2018 accepts, and the clause should name what is disclosed, to whom, and where it is held.
The Privacy Act 1988 runs alongside, and Australian Privacy Principle 8 governs cross-border disclosure of personal information. Not every business is covered by that Act, so check whether yours is rather than assuming either way. Some licensee agreements and government funding contracts carry their own data-location terms as well, so read yours.
The person who lodges is the person who carries the registration
Accept that sentence and most of the design questions answer themselves.
Your registered agent lodges. Not the preparer, and not you on the agent's behalf. Access to ATO Online services for agents runs through each individual's own Digital ID and their own authorisation in Relationship Authorisation Manager, so there is no version of this where a preparer signs in as somebody else. A team member without Australian identity documents applies for a Basic Digital ID, which carries restricted access in RAM. Credentials are never shared, and access is granted and revoked by the practice.
The client declaration is separate again. Section 388-65 of Schedule 1 to the Taxation Administration Act 1953 requires the client to make a written declaration before the agent lodges. Nobody in a support role signs it, approves it or supplies it on the client's behalf.
And when an arrangement fails, it fails against the registration. The TPB's position is that you may face administrative sanctions if your outsourcing arrangements breach the Code: written cautions, orders, or suspension or termination of registration. The preparer offshore does not carry that exposure. You do. Which is the real argument for writing the boundary down instead of trusting a capable person to infer it.
If you are doing your own BAS rather than a client's
The question changes shape. Nobody outside your business is relying on the work, and the consent question does not arise at all, because the information is your own rather than a client's.
What does not change is who lodges. Section 50-5 turns on a service provided for a fee or other reward, and whether a particular in-house arrangement sits inside or outside that description is a question worth putting to your own agent or to the TPB rather than settling by inference. We would not structure it that way regardless. The preparer prepares, and an authorised person inside your business reviews and lodges through their own Digital ID. That holds up on any reading of the Act, which is the point of choosing it.
What the TPB suggests you consider
The Board's outsourcing and offshoring factsheet sets out factors you may wish to weigh before entering an arrangement. Read them as a setup checklist rather than a compliance afterthought:
- Clearly defined duties, obligations and responsibilities on both sides
- How information is stored, accessed, transferred and archived
- Security protocols against unauthorised access, and protections preventing service disruption
- Liability and indemnity insurance arrangements
- Dispute resolution processes for client information
- The competency of the provider
- How you evaluate, oversee, amend or exit the arrangement
- Legislative and regulatory requirements for holding information offshore
Two of those deserve a specific mention. Code item 13 requires you to maintain professional indemnity insurance meeting the Board's requirements, and the TPB suggests reviewing your policy to assess whether appropriate coverage exists for outsourced services. That is one email to your broker, and a much better conversation to have now than at claim time. Code items 9 and 10, reasonable care in ascertaining a client's state of affairs and in ensuring the taxation laws are applied correctly, are also live here, because a reconciliation you did not genuinely check is not reasonable care.
The same factsheet notes that inadequate arrangements may also lead to contraventions of other legislation, including the Privacy Act 1988 and the Corporations Act 2001.
What to do next
Three things, in order. Write down on one page which acts in your BAS process require your registration and who performs them. Check the third-party disclosure clause in your engagement letters before any file moves. Then decide what the preparation role actually covers, which is easier from a written scope: ours is on the BAS preparation assistant page, alongside the rest of what we do for accounting firms.
If you want the same split applied to the other recurring work in a practice, handing over payroll and the client bookkeeper role cover the pay run and the ledger, and what an accounting firm should delegate first puts the whole lot in order.
When you are ready to talk about a specific role, book a discovery call. We hire the person in the Philippines and manage them; you set the boundary and keep the registration exactly where it has to be.
How we would staff the preparation side of a BAS cycle
Everything above sorts into two piles: work that is rule-bound and checkable, and judgement that belongs to your registered agent. We hire for the first pile only. StaffingSolutions.io hires the person in the Philippines and manages them, and they work inside your ledger under your coding rules, so your agent reviews a finished pack instead of rebuilding one.
- Codes the period to the GST treatment your firm has already recorded for that client, and lists exceptions rather than quietly correcting them
- Reconciles GST control accounts back to the ledger, clears suspense, and cross-checks PAYG withheld and super against the payroll reports for the period
- Keeps a dated query list so anything needing a position formed goes up to your agent instead of being answered offshore, which leaves a written record of what was escalated and how it was answered
- Builds one reconciliation pack per client with the figures, the workings, the exceptions and the open questions, so your reviewer checks a visible chain rather than trusting a number
- Runs the rolling deadline schedule and chases clients for missing information well before the lodgement window, not during it
- Forming the position. Whether a supply is GST-free, how an unusual transaction is treated, anything the client will rely on.
- Lodgement. Through your registered agent's own digital identity and authorisation for client work, or an authorised person inside your business for your own statement. No shared credentials and no preparer signing in as somebody else.
- The client's written declaration before lodgement. Nobody in a support role signs it, approves it or supplies it on the client's behalf.
- Client consent obtained before any file moves, the supervision you can actually evidence, and a professional indemnity policy you have checked covers outsourced work.
Frequently asked questions
What can an offshore assistant actually do on a BAS?
How much does it cost to outsource BAS preparation to the Philippines?
Does my professional indemnity insurance cover work prepared overseas?
Can offshore staff talk to my clients about their BAS?
Does the Privacy Act apply when client data goes to the Philippines?
Can I give an offshore bookkeeper access to Xero or MYOB?
- Tax Agent Services Act 2009 (Cth) ss 90-10, 50-5 and 30-10 — What counts as a BAS service, the civil penalty for providing one unregistered for a fee, and the Code of Professional Conduct that follows the work offshore
- Tax Practitioners Board, "Information for tax practitioners: Outsourcing and offshoring" (factsheet, NAT 75791-07.2026) — Code items 6, 7, 9, 10 and 13 applying to unregistered contractors abroad, the sanctions exposure, and the factors to consider before entering an arrangement
- Tax Practitioners Board, TPB(GS) 31/2018 Outsourcing and offshoring of tax services — A third-party consent clause in the engagement letter as an accepted way to obtain client consent before disclosure
- Tax Practitioners Board, TPB(GS) 53/2024 (guidance on supervision and control) — That checking whether a document looks reasonable is not enough, and there must be substantial supervision
- Taxation Administration Act 1953 (Cth) sch 1 s 388-65 — The written client declaration required before a registered agent lodges
- Privacy Act 1988 (Cth) sch 1, Australian Privacy Principle 8 (OAIC) — Cross-border disclosure of personal information, subject to whether the Act covers your business
- Australian Taxation Office guidance on myID, Basic Digital ID and Relationship Authorisation Manager — Individual authorisation for Online services for agents, restricted access on a Basic Digital ID, and no shared credentials
Alfie is a natural facilitator with a passion for building meaningful relationships. A true people person, he thrives on creating genuine connections and bringing people and businesses together, and he excels at fostering collaboration and teamwork. At StaffingSolutions.io he is usually the first person you speak to: he maps the role, writes the brief the recruiters work from, and stays on the account long after the placement.
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