Country-specific guidance Current

TPB client record-keeping standard for tax practitioners

What counts as a proper client record, not just any record.

Keeping some notes about a client isn't the same as meeting the TPB's obligation to keep proper client records. This guide sets out what that standard actually expects. It is general information, not tax or compliance advice.

Action plan

1 Record the nature, scope, and outcome of each service A proper client record needs to show what was actually done, not just that something happened.

The TPB's obligation to keep proper client records requires records that correctly record the tax agent or BAS services provided to each client, showing the nature, scope, and outcome of the service. This extends to the terms of engagement, advice given, decisions made, and client communications, not only the final output.

  • Record the nature and scope of each service provided to a client
  • Record the outcome, including advice given and decisions made
  • Keep the terms of engagement and material client communications as part of the record

Done when: Client records capture the nature, scope, outcome, and material communications of each service, not just the final output

TPB: obligation to keep proper client records
2 Keep records in English, or readily convertible into English A record that can't be quickly reviewed in English doesn't meet the standard, even if it's complete.

The TPB's obligation requires records to be in English, or readily accessible and easily convertible into English. Where a record originates in another language, keep a readily accessible English version or translation alongside it rather than relying on the original alone.

  • Keep client records in English where practicable
  • Where a record originates in another language, keep it readily convertible into English
  • Don't rely on an untranslated record as satisfying the standard on its own

Done when: Client records are in English or readily accessible and easily convertible into English

3 Retain records for at least 5 years after the service The retention clock runs from when the service was provided, not from when the client relationship ends.

The TPB's obligation requires records to be retained for at least 5 years after the service has been provided. Track this per service rather than assuming a single retention date applies to everything in a long-standing client's file.

  • Retain each service's record for at least 5 years from when that service was provided
  • Track retention per service, not as a single date for the whole client relationship
  • Confirm your firm's retention schedule reflects this minimum

Done when: A retention schedule consistent with the 5-year minimum is applied per service

See setting a record-retention schedule for compliance evidence