Published 28 July 2026 · Covers 2020 to July 2026 · Prime People

Before the list, the reassurance. None of what follows changes what accounting is. The framework of Australian tax and the shape of a compliance job are where you left them. What has moved is a set of specific positions inside that framework, and the plumbing around lodgment and payroll.

Some of it is so recent that people who never left are learning it at the same time you are. Payday Super started three weeks before this was written. The Bendel decision landed seven weeks ago. On those two, there is no gap between you and the person who stayed.

Tax technical

Bendel: unpaid present entitlements are not Division 7A loans

This is the big one, and it is recent enough that it will almost certainly come up in conversation.

On 10 June 2026 the High Court decided Commissioner of Taxation v Bendel [2026] HCA 18, dismissing the Commissioner's appeal five to two. The effect is that where a private company beneficiary does nothing about its entitlement to trust income, no loan arises for Division 7A purposes. Inaction in calling for payment of an unpaid present entitlement is not, of itself, a loan.

If you left before this, you were taught the opposite. For well over a decade the ATO's position was that a UPE retained by the trust could be a Division 7A loan, which drove the whole apparatus of complying loan agreements and sub-trust arrangements around bucket companies. That apparatus has been the standard year-end conversation in every business services team in the country.

The ATO has published a decision impact statement, dated 26 June 2026, and has noted that PCG 2022/2 is being reviewed as a result. Practical guidance is still settling, which is worth knowing, because the correct thing to say about Bendel in an interview right now is that the principle is clear and the downstream consequences are not yet fully worked through.

Section 100A: the zones you may have missed

If you left before 2022 you may not have worked with the section 100A guidance in its current form. Taxation Ruling TR 2022/4 sets out the Commissioner's view on reimbursement agreements, and Practical Compliance Guideline PCG 2022/2 sorts arrangements into a green zone the ATO will not generally review, a red zone it will, and a white zone for pre-2014 arrangements.

In day to day terms this is what turned trust distribution resolutions from a June formality into a documented annual exercise, particularly distributions to adult children. If your last trust season was 2019, this is the single largest change in how that work gets done.

Payroll and superannuation

This is where the most has moved, and where a returner is most likely to be caught out on something basic.

From What changed
1 Jan 2022 STP Phase 2 mandatory. Payroll reporting became more granular, disaggregating gross income into its components so data can be shared with Services Australia. Many employers moved later under deferrals granted through their software provider.
1 Jul 2025 Super guarantee reached 12%. The end of the legislated step-ups. If you left when it was 9.5% or 10%, this is a four-year climb you did not watch.
1 Jul 2026 Payday Super. Super is paid with every pay run, not quarterly. It must be received by the fund within 7 business days of payday to avoid the super guarantee charge, it is calculated on qualifying earnings rather than ordinary time earnings alone, and year to date qualifying earnings are reported through STP each payday.
1 Jul 2026 The Small Business Superannuation Clearing House closed. Employers who used it have had to move to a commercial clearing house or their payroll provider's solution.

Payday Super is worth understanding properly rather than in outline, because it is the live operational problem in every firm with payroll clients right now. The seven business day rule and the shift to qualifying earnings mean the old quarterly rhythm, and the habit of catching up super in the month after quarter end, are simply gone. Nobody has a full cycle of experience with it yet.

Dealing with the ATO

Client to agent linking

From 13 November 2023 the ATO extended client to agent linking to all entity types with an ABN, excluding sole traders. That covers companies, trusts, partnerships, super funds and not-for-profits.

The practical effect: the client has to nominate you in Online services for business before you can be added as their agent. You cannot simply add them from your end any more. Existing arrangements that do not change are unaffected, but new clients, and new authorisations for existing clients, now start with a nomination the client must complete themselves within a limited window.

It is a security control against agent-linked identity fraud and it is entirely sensible. It is also, in daily practice, the single most common source of onboarding friction in Australian firms, and if you are asked what you know about it, the answer that lands is that it moves the first step of onboarding onto the client and you have to plan for that.

How the profession is regulated

The 2024 Code Determination

The Tax Agent Services (Code of Professional Conduct) Determination 2024 was registered on 2 July 2024 and added eight obligations under Code item 17. They cover upholding and promoting the ethical standards of the profession, addressing false or misleading statements, managing conflicts of interest in dealings with government, keeping proper client records, ensuring competency and maintaining quality management systems, and keeping clients informed.

Commencement was staged: 1 January 2025 for larger practitioners, and 1 July 2025 for practitioners with 100 or fewer employees as at 31 July 2024, which is most Australian firms.

The one with the most day to day bite is the obligation around false or misleading statements, because it reaches statements made by others in circumstances the practitioner knows about. In firms this has generally translated into more documented file notes, more explicit client sign-off, and more attention to what happens when a client declines to correct something. If you are interviewing at manager level or above, being able to say that is useful.

How firms actually work now

Everything above is sourced. This section is observation from the firms we recruit for, so weigh it accordingly.

  • The client ledger is cloud by default. The transition was well under way before 2020 and is now essentially complete in the small and medium business market. The consequence is less rekeying and more reviewing, and a bookkeeping layer that is often already done when the file reaches you.
  • Workflow moved into practice management systems. Job tracking, capacity planning and review sign-off increasingly live in a single system rather than a spreadsheet and a partner's memory. Which system varies by firm, and no firm expects you to arrive knowing theirs.
  • Hybrid settled somewhere around two to three days in the office in most Sydney firms, having swung further both ways in between. It is now negotiated rather than assumed, which is good news if you need a specific pattern.
  • AI assistance is arriving in workpapers and correspondence, unevenly, and mostly as drafting and extraction support rather than anything that forms a conclusion. The review obligation has not moved anywhere, and the Code obligations above are part of why. This is early and firms are working out their own policies.

The interview version of all this. You do not need to have mastered any of it. You need to be able to name two or three developments, say what they mean operationally, and be honest that you have read about them rather than worked with them.

Someone who says "I have read the Bendel judgment and I understand the principle, but I have not yet seen how the firm is handling existing sub-trust arrangements" sounds like a professional. Someone who claims fluency they do not have gets found out in the first month, which is a much worse outcome than admitting the gap in the interview.

What has not changed

Worth saying plainly, because the list above can read as more disruption than it is.

The structure of Australian tax is where you left it. Trusts still distribute, companies still frank, individuals still have a marginal rate scale, the small business concessions still exist, and the CGT rules that took you two years to internalise are unchanged. Financial reporting has not been reinvented. A set of accounts still has to balance and still has to be explicable to someone who does not read accounts.

And the actual work of the job is identical. Someone brings you a mess. You work out what happened, what it means, what it costs, and what they should do. That has not changed since long before you left and it is the part nobody has worked out how to automate or teach quickly.

Frequently asked questions

What is Payday Super and when did it start?

It started 1 July 2026. Super guarantee is paid each payday rather than quarterly, must be received by the fund within 7 business days of payday to avoid the super guarantee charge, is calculated on qualifying earnings, and year to date qualifying earnings are reported through STP each payday. The Small Business Superannuation Clearing House closed at the same time.

What did the High Court decide in Bendel?

On 10 June 2026, by five to two, that a private company beneficiary which does nothing about its entitlement to trust income has not made a Division 7A loan. Inaction in calling for payment of a UPE is not, of itself, a loan. It displaced more than fifteen years of ATO practice, and PCG 2022/2 is under review as a result.

What are the new Code obligations?

Eight additional obligations under Code item 17, introduced by a determination registered on 2 July 2024, covering ethical standards, false or misleading statements, conflicts of interest with government, client records, competency and quality management, and keeping clients informed. They applied from 1 January 2025 for larger practitioners and 1 July 2025 for those with 100 or fewer employees as at 31 July 2024.

What is client to agent linking?

The client nominates you in Online services for business before you can be added as their agent. It applied to all ABN holders except sole traders from 13 November 2023. Unchanged existing arrangements are unaffected, but new clients and new authorisations start with a client-side nomination.

What is the super guarantee rate now?

12%, reached on 1 July 2025. Under Payday Super it is 12% of qualifying earnings.

When did STP Phase 2 become mandatory?

1 January 2022, though many employers transitioned later under deferrals through their software provider. It disaggregates gross income into components so payroll data can be shared with Services Australia.

Sources

All sources accessed 28 July 2026. This briefing is general information for people considering a return to public practice, not tax, legal or financial advice, and it is a summary rather than a statement of the law. Tax law and ATO guidance change frequently and the position on Division 7A is actively developing following Bendel. Check the primary sources above, or take advice, before relying on any of it in client work. We intend to refresh this page annually.

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