Published 26 July 2026 · North Sydney · Prime People
No, not for a fee, unless that bookkeeper is also a registered tax agent.
Preparing and lodging an income tax return is a tax agent service under the Tax Agent Services Act 2009, and only a registered tax agent can provide one for a fee or other reward. Plenty of bookkeepers are registered BAS agents, which is a different and narrower registration. It covers GST, PAYG and related BAS provisions. It does not reach income tax returns.
Some bookkeepers do hold both registrations. The only reliable way to know is to look them up on the TPB public register, which is free and takes under a minute.
That is the whole answer. The rest of this page is the detail, because the two registrations get conflated constantly, and the consequences of getting it wrong land on both sides: on the practitioner who provides a service they are not registered for, and on the business owner who assumed their books person had it covered.
Two registrations, one register
The Tax Agent Services Act 2009 does not regulate job titles. It regulates services provided for a fee or other reward, and it splits them into categories. The Tax Practitioners Board administers the register.
A tax agent service is defined by the TPB as a service relating to "ascertaining (that is, working out) or advising about liabilities, obligations or entitlements of entities… under a taxation law", or representing them in dealings with the Commissioner of Taxation, "where it is reasonable to expect the entity will rely on the service".
A BAS service is a subset. It is a tax agent service that relates specifically to a BAS provision. The BAS provisions are defined in the Income Tax Assessment Act 1997 and cover the indirect tax laws (GST, wine equalisation tax, luxury car tax, fuel tax), the PAYG system, the collection and recovery parts of fringe benefits tax, and a couple of others.
Read that list again and notice what is missing. Income tax is not a BAS provision. That single fact is the whole answer to the question in the title.
What each one can legally do
| Service, provided to a client for a fee | BAS agent | Tax agent |
|---|---|---|
| Prepare and lodge a business activity statement | Yes | Yes |
| Advise on GST, fuel tax credits, wine or luxury car tax | Yes | Yes |
| Work out PAYG withholding obligations for a client's employees | Yes | Yes |
| Payroll services that involve interpreting and applying a taxation law, including STP set-up and reporting | Yes | Yes |
| Superannuation guarantee: calculating an SG shortfall, preparing and lodging an SGC statement, dealing with the ATO on the SGC account | Yes, under the Specified BAS Services No. 2 Instrument 2020 | Yes |
| Apply for an ABN on a client's behalf | Yes | Yes |
| Prepare and lodge an income tax return | No | Yes |
| Advise on a taxation law generally, where the client will rely on it | No, only in relation to BAS provisions | Yes |
| Prepare depreciation schedules on deductibility of capital expenditure | No | Yes |
| Lodge an objection against an assessment under Part IVC | No | Yes |
| Advise on FBT (beyond collection and recovery), CGT, Division 7A or salary packaging | No | Yes |
Compiled from the Tax Practitioners Board's published definitions and its non-exhaustive example tables for BAS services and tax agent services, accessed 26 July 2026. Individual registrations can carry conditions that narrow them further, so the register is the authority for any particular practitioner. General information only, not advice.
The exception almost everyone means but nobody states
When someone says "our bookkeeper does our BAS", they are usually describing an employee. That is a different situation and it is generally fine.
Registration is triggered by providing the service to a client, for a fee or other reward. An employed bookkeeper preparing their own employer's BAS as part of their job is not charging a client. No registration requirement is triggered. The same person doing exactly the same work for three outside businesses and invoicing them is providing BAS services for a fee, and needs to be registered.
There is a wrinkle if the employer is itself a registered practice. The TPB lists an exemption for "an employee or contractor of a registered tax agent" who does not provide tax agent services in their own right, but adds that a registered company or partnership "might need you (as an individual) to be registered so that it has a sufficient number of registered individual tax agents". If you run a practice, that sufficient-number requirement is a live compliance question every time you hire or lose someone, and it is not one to work out from a blog post.
What this means if you are hiring. "Bookkeeper" on a CV tells you nothing about what the person can legally do for your clients. Ask for the registration type and the agent number, then check it on the register before you make the offer. We do this as a matter of course on any role where the work touches client BAS, and it takes less time than reading the CV did.
What it takes to hold each registration
The gap between the two is not a formality. It is years.
For a BAS agent, the Tax Agent Services Regulations 2022 set out two pathways. Both require at least a Certificate IV in bookkeeping or accounting from a registered training organisation, plus a Board-approved course in basic GST/BAS taxation principles. The difference is experience: 1,400 hours of relevant experience in the past four years, or 1,000 hours if you are a voting member of a recognised BAS or tax agent association.
For a tax agent, there are six pathways. The common one for accountants is a degree or postgraduate award in accounting, plus Board-approved courses in Australian taxation law and commercial law, plus one year of full-time relevant experience in the past five years. Without a degree it gets much longer: the diploma pathway requires two years of experience, and the work-experience-only pathway requires eight years in the past ten.
So a bookkeeper asking "how do I get to do tax returns" is really asking about a degree and a professional program. That is the same conversation as how to become an accountant in Australia, and it ends at choosing between CA and CPA.
Penalties, briefly
The TPB does not hedge on this. On BAS services it warns of "significant civil penalties for anyone providing BAS services for a fee or reward, or advertising BAS services, while unregistered". On tax agent services: "severe penalties for anyone providing tax agent services for a fee or reward, advertising tax agent services or representing as a registered tax agent while unregistered".
Note that advertising is enough on its own. You do not have to have done the work.
How to check the register properly
- Go to the TPB public register and search the person's or the firm's name.
- Check the registration type. Tax agent and BAS agent are different entries, and this is the step people skip.
- Check the status is current, not lapsed, suspended or terminated.
- Check for conditions. The Board can impose conditions that limit the scope of services someone may provide, so a registration is not always the full set.
If the person is trading through a company or partnership, the entity needs its own registration as well as having registered individuals behind it. Search both.
Frequently asked questions
Can a bookkeeper do my tax return?
Not for a fee, unless they hold tax agent registration. An income tax return is a tax agent service, and BAS agent registration does not cover it. Check the register rather than asking.
What is the difference between a BAS agent and a tax agent?
A BAS agent can provide services relating to BAS provisions: GST, PAYG withholding and instalments, fuel tax credits, wine and luxury car tax, and superannuation guarantee matters under a 2020 legislative instrument. A tax agent can provide the full range of tax agent services under any taxation law, which includes everything a BAS agent can do plus income tax returns, objections, depreciation schedules and general tax advice.
Can a bookkeeper lodge a BAS?
Yes, if registered as a BAS agent. An unregistered bookkeeper cannot provide BAS services to clients for a fee, and the TPB warns of significant civil penalties for doing so, including for merely advertising the service.
Does our in-house bookkeeper need to be a registered BAS agent?
Generally no, because registration is triggered by providing the service to clients for a fee. An employee preparing their own employer's BAS is not charging a client. The answer changes if your business is itself a registered tax or BAS agent practice, which has to maintain a sufficient number of registered individuals.
Can a bookkeeper give tax advice?
A registered BAS agent can advise on BAS provisions, so GST treatment and PAYG obligations are within scope. Advice on income tax, capital gains, Division 7A or salary packaging is not, and giving it for a fee without tax agent registration is the exact conduct the penalties are aimed at.
Is it cheaper to use a BAS agent than an accountant?
For BAS work, usually. But the comparison only holds where the work genuinely sits inside the BAS provisions. If the question is really about your income tax position, a cheaper hourly rate for the wrong registration is not a saving.
Sources
- Tax Practitioners Board, Tax agent services (definition per section 90-5 TASA, example table, penalties). Accessed 26 July 2026.
- Tax Practitioners Board, BAS services (definition per section 90-10 TASA, BAS provisions list, Tax Agent Services (Specified BAS Services No. 2) Instrument 2020, example table, civil penalties). Accessed 26 July 2026.
- Tax Practitioners Board, Qualifications and experience for BAS agents (TASR items 101 and 102: Certificate IV, GST/BAS course, 1,400 or 1,000 hours). Accessed 26 July 2026.
- Tax Practitioners Board, Qualifications and experience for tax agents (TASR items 201 to 206, experience requirements). Accessed 26 July 2026.
- Tax Practitioners Board, Apply to register (who needs to register, registration exemptions, sufficient number requirement). Accessed 26 July 2026.
- Tax Practitioners Board, Public register. Accessed 26 July 2026.
General information only, current at the date of publication. It is not tax, legal or financial advice and does not take your circumstances into account. Registration requirements and legislative instruments change; the TPB is the authority. If you are unsure whether a service you provide requires registration, get advice before you invoice for it.
Recruiting for a role that touches client BAS?
We check TPB registration as standard on any brief where it matters, because "bookkeeper" on a CV does not tell you what the person is registered to do.
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