Below is an overview of some key considerations and practical steps you might take when building a system of quality management for a tax agent practice (or any professional services firm). These suggestions are aligned with the intent of the standards issued by the Accounting Professional & Ethical Standards Board (e.g., APES 320 Quality Control for Firms, APES 110 Code of Ethics for Professional Accountants), as well as the broader obligation to comply with the Code of Professional Conduct under the Tax Agent Services Act 2009.

1. Governance and Leadership

   a. Leadership commitment and tone at the top

• • Demonstrate clear commitment from senior leaders (e.g., partners, directors, or principals) to quality and ethical standards.
  • Communicate regularly and consistently about the importance of ethics, professionalism, and client care.
  • Assign specific individuals to be responsible for quality management within the practice. 

• b. Risk appetite and resource allocation

• • Define what “acceptable risk” looks like in delivering tax agent services.
  • Allocate sufficient resources (human, technological, financial) to ensure the quality system is built, maintained, and improved over time.

2. Risk Assessment and Control Environment

   a. Identifying and assessing risks

• • Identify the inherent risks your practice faces (e.g., areas prone to error in tax return preparation or advisory services, new legislation risks, client acceptance risks).
  • Assess the likelihood and impact of these risks.
  • Prioritize those risks that have the greatest potential to harm clients or the firm’s compliance with the Code of Professional Conduct.

• b. Designing and implementing controls

• • Develop policies and procedures that address identified risks (e.g., second reviewer sign-off for complex returns, conflict checks for new clients).
  • Ensure controls are clearly documented, accessible, and understood by everyone in the practice.

3. Documentation of Policies and Procedures

   a. What to include

• • Clearly written and up-to-date firm policies covering:
    • Client acceptance and continuance (including due diligence and conflict checks)
    • Engagement letters and scope of services
    • Management of client information (confidentiality and data protection)
    • Record-keeping and file management
    • Ethical considerations and the practice’s position on independence and conflicts of interest
    • Procedures for identifying and responding to breaches of ethical or legal requirements

• b. Ensuring currency and accessibility

• • Keep policy documents current with legislation changes (e.g., new ATO rulings, TASA updates) and relevant professional standards (e.g., updates from APESB).
  • Make them easily accessible (e.g., via internal intranet or a shared document system).

4. Engagement Performance and Monitoring

   a.Setting up robust engagement processes

• • Use standardised templates for engagement letters, checklists for tax return preparation, and review processes to help ensure consistency.
  • Consider implementing workflow software or practice management systems that track deadlines, tasks, and responsibilities.
    
    
• b. Ongoing monitoring

• • Perform periodic quality reviews of completed engagements (e.g., a partner or senior manager might randomly sample engagements for compliance).
  • Track, document, and report on key performance indicators (e.g., percentage of returns lodged on time, error rates, or feedback from clients).

5. Recruiting, Training, and Managing Personnel

   a. Hiring

• • Develop a recruitment policy that emphasises technical competence, ethical behavior, and communication skills.
  • Conduct thorough reference checks to ensure new employees or contractors have no unresolved compliance or ethical issues.
    
    
•  b. Training and development

• • Provide ongoing professional development on changes to tax legislation, ethical standards, and internal procedures.
  • Use a combination of in-house training, external courses, and online learning.
  • Encourage professional certification (e.g., CA, CPA, CTA) where relevant.
    
    
• c. Performance management

• • Incorporate quality and compliance measures into performance evaluations.
  • Provide constructive feedback when issues arise, and offer additional training or supervision as needed.

6. Protecting Confidentiality

   a. IT and data security

• • Implement password policies, encryption, and secure document-sharing protocols.
  • Use reputable software providers for client data storage and processing.
  • Restrict access to client data on a need-to-know basis.
    
    
• b. Physical security

• • If you maintain paper records, ensure they are stored in locked cabinets or rooms with restricted access.
  • Have protocols for proper destruction (shredding) or archiving of documents.

7. Handling Conflicts of Interes

   a. Identifying conflicts

• • Set up a system (e.g., a client or matter database) for conflict checks when accepting new clients or new engagements.
  • Train staff to spot potential conflicts early (e.g., two clients involved in the same transaction).
    
    
• b. Managing conflicts

• • Where a conflict is identified, consider whether it can be managed (e.g., by disclosing to both parties, obtaining informed consent, establishing information barriers) or whether declining the engagement is the most ethical action.

8. Internal Review and Continuous Improvement

   a. Internal reviews

• • Regularly assess whether your quality management system is performing as intended.
  • Document findings and identify areas for improvement.
    
    
• b. External peer review (where applicable)
  • In some professional settings, external peer reviews or professional body reviews may be required or recommended.
  • Use feedback from these reviews to strengthen internal processes.

• c. Action plans and follow-up

• • When improvement opportunities are identified (e.g., gaps in procedures, training needs, new regulatory requirements), create an action plan with clear accountabilities and deadlines.
  • Reassess and update the quality management system accordingly.

9. Dealing with Breaches or Complaints
   a. Establish a clear process

• • Have a documented procedure for lodging and handling complaints—both from clients and from within the firm.
  • Ensure complaints are investigated independently, promptly, and fairly.
    
    
• b. Remedial actions

• • If a breach of the Code or legislation is found, take corrective actions such as additional training, policy refinements, or disciplinary measures (if necessary).
  • Communicate outcomes where appropriate to reinforce a culture of accountability and continuous improvement.

10. Staying Current with Regulatory and Ethical Standards

    a. Monitor changes

• • Assign responsibility for staying abreast of changes in tax law, TASA requirements, and APESB standards.
  • Subscribe to relevant regulatory bodies’ newsletters (e.g., Tax Practitioners Board, ATO, APESB) and professional associations (e.g., CA ANZ, CPA Australia, The Tax Institute).
    
    
• b. Periodic system reviews

• • Formally review the entire quality management system at least annually or when major regulatory or operational changes occur.
  • Involve management and, if necessary, external advisors to ensure objectivity.

Conclusion

Building and maintaining a quality management system is not just a “check-the-box” exercise—it is an integral part of delivering professional, ethical, and client-focused tax agent services. By embedding robust governance, clear policies, ongoing monitoring, and a culture of integrity, you can gain the reasonable confidence needed to demonstrate compliance with the Code of Professional Conduct and continually uphold a high standard of client service.

Remember that each practice is unique; tailor these elements to suit your firm’s size, complexity, and the nature of services you offer. When in doubt, consider seeking external advice or peer support to ensure your quality management system remains fit for purpose and up to date with evolving professional requirements.