Document title: CAAA Group Terms of Business
Version: 2026.1
Effective date: 01-07-2026
Applies to: New and continuing Services provided by the CAAA Group, including Services for current clients after notice and acceptance.

Website location WWW.CAAA.BIZ

1. How these Terms apply, including current clients and future updates

These Terms of Business (Terms) apply to the Services provided by the CAAA entity named in the relevant engagement letter, confirmation letter, schedule or other written engagement document accepted by CAAA.

The agreement between CAAA and the client(s) comprises:

1. the engagement letter;
2. these Terms, as updated from time to time in accordance with this clause;
3. any confirmation letter, schedule, authority, fee proposal or written instruction accepted by CAAA; and
4. any written variation agreed by CAAA.

The documents that make up our agreement are intended to be read together. If there is any inconsistency between them, the following order of priority applies, from highest to lowest: (1) any later written variation or confirmation accepted by CAAA, to the extent of the subject matter it deals with; (2) the engagement letter, for terms specific to your engagement, including scope, fees and any special conditions; and (3) these Terms of Business.

For new clients: these Terms apply from the date you accept the engagement or first instruct CAAA to proceed with the Services, after having been provided with the engagement letter.

For current clients: including clients who accepted an earlier engagement letter or an earlier version of CAAA’s terms of business, these Terms apply to Services requested, continued or provided on or after the Effective Date if CAAA has notified you of these Terms, provided you with a copy, or made them available to you, and you continue to instruct CAAA, provide information, request work or accept Services after that date.

These Terms replace any earlier CAAA Terms of Business for future and continuing Services from the Effective Date. They do not retrospectively alter rights or obligations that accrued before the Effective Date, change fees already charged for completed work, or alter terms applying to Services already completed, unless agreed in writing or permitted by law.

CAAA may update these Terms from time to time, including to reflect changes in law, regulation, professional standards, technology, privacy, AML/CTF, TPB requirements, operational processes, billing processes or practice risk settings. If an update is material, CAAA will give reasonable notice by email, client portal, website link, invoice note, engagement letter, confirmation letter or other written communication and will identify the version or effective date of the updated Terms.
Updated Terms apply to Services requested, continued or provided after the stated effective date if you continue to instruct CAAA, provide information, request work or accept Services after receiving notice of the update. If you do not agree to the updated Terms, you must notify CAAA before requesting or accepting further Services. CAAA may then suspend or terminate the engagement, issue a new engagement letter, or agree different terms in writing.

No update to these Terms will exclude or restrict any right, remedy, guarantee, duty or liability that cannot lawfully be excluded or restricted, or override a client-specific scope, fee arrangement or special condition that CAAA has expressly agreed in writing, unless CAAA expressly agrees otherwise in writing.

2. Services, scope and changes

CAAA will provide the Services described in the engagement letter, confirmation letter, schedule, fee proposal or written instruction accepted by CAAA.
Only the Services specifically selected or described in the engagement letter are covered by the fees specified in the engagement letter. Additional services may be subject to additional fees, further client due diligence and/or a separate or amended engagement letter.

Unless expressly agreed in writing, we will not conduct an audit, review or assurance engagement and no assurance opinion will be expressed. Unless separately agreed in writing, the Services do not include financial product advice, tax (financial) advice, legal advice, insolvency advice, valuation services, forensic accounting, due diligence, expert witness work or advice on laws outside Australia.

Timeframes and deadlines are estimates or planning dates unless CAAA expressly agrees in writing that a date is contractually binding. You must provide complete instructions and information in sufficient time for CAAA to meet lodgement and other deadlines.

Either party may request changes to the Services. No change will bind CAAA unless accepted by CAAA in writing or by CAAA continuing to perform the additional work. Additional services may be subject to additional fees, further client due diligence and/or a separate or amended engagement letter.

CAAA may change the personnel who perform or supervise the Services, provided that CAAA continues to apply appropriate professional supervision and quality management.

3. Professional standards and legal obligations

CAAA will perform the Services with professional competence and due care and in accordance with applicable legal, professional and ethical obligations. These may include, depending on the Services, APES 110 Code of Ethics for Professional Accountants (including Independence Standards), APES 220 Taxation Services, APES 305 Terms of Engagement, APES 315 Compilation of Financial Information, APES 205 Conformity with Accounting Standards, APES 310 Client Monies and APES 320 Quality Management for Firms.

Relevant legislation and regulatory requirements may include the Corporations Act 2001 (Cth), Tax Agent Services Act 2009 (Cth), Tax Agent Services Regulations 2022 (Cth), Tax Agent Services (Code of Professional Conduct) Determination 2024, Privacy Act 1988 (Cth), Competition and Consumer Act 2010 (Cth), Consumer Data Right rules, Anti-Money Laundering and Counter-Terrorism Financing Act 2006 (Cth), sanctions laws and associated rules, to the extent applicable to the Services.

References to legislation, regulations, standards and regulatory guidance are references to those instruments as amended, replaced or updated from time to time.
We have a duty to act in your best interests, unless that duty is inconsistent with our duty to act in the public interest or with a legal, regulatory or professional obligation. If we identify or suspect non-compliance with laws or regulations, we may be required or permitted to make disclosures to an appropriate authority, regulator, professional body or auditor, including without prior notice to you where required or permitted by law or professional standards.

4. Your responsibilities

You are responsible for:

• making full and frank disclosure of all information relevant to the Services, including information that may affect taxation, accounting, reporting, corporate, ASIC, payroll, superannuation, AML/CTF or other obligations;
• maintaining your own books, records, source documents, substantiation, corporate records and other records required by law;
• providing all information, documents, explanations, instructions and approvals reasonably requested by CAAA in sufficient time to meet applicable deadlines;
• ensuring that all information provided to us is reliable, accurate, complete and not false or misleading, including by omission;
• reviewing all returns, statements, reports, advice, correspondence and documents prepared by us before they are lodged, issued or relied upon, and promptly notifying us of any error or concern;
• notifying us promptly of any change in your circumstances, ownership, control, structure, address, contact details, directors, trustees, beneficiaries, officeholders, business activities, tax residency, financial position, risk profile or other matters relevant to the Services;
• ensuring that any person who gives instructions or provides information to us on your behalf is authorised to do so; and
• complying with your obligations to the ATO, ASIC, AUSTRAC, Revenue NSW, other revenue offices and other regulators, including payment, lodgement, record-keeping and disclosure obligations.

You remain responsible under the self-assessment system for keeping full and proper records and for the accuracy and completeness of information provided to us.

5. Authority to instruct and multiple clients

Unless you notify us otherwise in writing, each client authorises every other client listed in the engagement letter to give instructions and information to us, and to receive advice, documents and communications from us, on behalf of all client(s) listed in the engagement letter.

If we receive inconsistent or conflicting instructions, we may decline to act on those instructions until all relevant client(s) confirm the position in writing.

6. Tax, BAS and compilation services

To the extent the Services include tax agent services or BAS services, you authorise CAAA, through its registered tax practitioners and authorised personnel, to use the ATO, tax agent, BAS agent and other government portals and communication channels for the purpose of managing, preparing, lodging and advising on your taxation, BAS, superannuation and related obligations within the agreed scope. Any tax advice we provide is an opinion based on our understanding of your particular circumstances and the information made available to us at the time.

Where CAAA provides tax agent services or BAS services, CAAA is required to provide clients with information about the Tax Practitioners Board (TPB) public register, the TPB complaints process, prescribed events and matters that may be relevant to your decision to engage or continue to engage CAAA, and general information about our rights, responsibilities and obligations as a registered tax practitioner and your obligations to us and under taxation laws.

To meet our obligations to keep you informed under the Tax Agent Services (Code of Professional Conduct) Determination 2024, we confirm that you can access the TPB public register and the TPB complaints process at tpb.gov.au, and that information about your and our respective rights, responsibilities and obligations is available to you. We will advise you, in a clear and prominent way, of any prescribed event affecting our registration in the last five years, or confirm that there are none. If we become aware that a statement made to the ATO or the TPB is materially false, incorrect or misleading, we must take the steps required of us, which may include asking you to correct it and, in some circumstances, withdrawing from the engagement and notifying the ATO or the TPB.

To the extent the Services include preparation or compilation of financial statements or financial information, those reports will be prepared in accordance with the financial reporting framework or basis of accounting described in the financial statements. You are responsible for the form and content of that information, the applicable reporting framework, accounting records and disclosures, and the intended use and users of the financial report.

You acknowledge that we may refuse to lodge or submit information where we know, or ought reasonably to know, that it is false or misleading in a material particular, including by omission.

7. Consumer Data Right

You may authorise an Accredited Data Recipient under the Consumer Data Right (CDR) regime to provide CDR data to us via a Trusted Adviser Insight. For this purpose, you may nominate CAAA as your Trusted Adviser, provided CAAA is permitted to receive that information under the CDR rules and any applicable professional, privacy and confidentiality obligations. CAAA may rely on information received through a Trusted Adviser Insight for the purpose of providing the Services.

8. AML/CTF, sanctions and customer due diligence

From 1 July 2026, the Anti-Money Laundering and Counter-Terrorism Financing Act 2006 (Cth) and the associated Rules apply to a range of accounting, taxation, corporate, and trust and company service provider services. Where we provide a designated service, we are a reporting entity and must comply with those obligations. This means we must carry out customer due diligence before, or as a condition of, providing the relevant service, conduct ongoing customer due diligence while we act for you, and we may be unable to commence or continue a designated service until the required due diligence is complete.

Where CAAA is a reporting entity or is otherwise required to comply with the Anti-Money Laundering and Counter-Terrorism Financing Act 2006 (Cth), associated rules, sanctions laws or related regulatory requirements, we may be required to collect, verify and maintain information about you, any person on whose behalf you are receiving Services, your representatives, beneficial owners, controllers, trustees, beneficiaries, officeholders and other related parties.

This may include information required to verify identity, authority to act, beneficial ownership and control, source of funds and/or source of wealth, the nature and purpose of the business relationship or transaction, politically exposed person status, targeted financial sanctions status, and other information relevant to assessing and managing money laundering, terrorism financing, proliferation financing and sanctions risks.

You must promptly provide information and documents reasonably requested by CAAA and must notify us if relevant information changes. We may conduct searches of appropriate databases or use electronic verification services.

If we are required or permitted by law to make a report or disclosure to AUSTRAC, the ATO, the TPB, a sanctions authority, a law enforcement agency, a professional body, a regulator or another authority, you acknowledge that we may do so without notice to you and that the law may prohibit us from informing you that a report or disclosure has been made.

If we are unable to complete required customer due diligence, or if AML/CTF, sanctions, fraud, tax integrity or other legal or ethical concerns arise that cannot be satisfactorily resolved, we may delay, suspend, refuse to provide or terminate the Services without liability, and without giving reasons where we are prohibited by law or where giving reasons would be inappropriate.

9. Third parties, outsourcing and cloud computing

We may from time to time engage, consult with or use third party specialist professionals, other public practitioners, contractors, technology providers, cloud service providers, outsourced service providers and CAAA group or related personnel to assist us to provide the Services or to obtain specialist input where appropriate.
Our outsourcing and cloud computing arrangements may involve personnel, service providers and technology platforms located in Australia and overseas. This may include, where applicable, accounting, tax, bookkeeping, administrative, data processing, document management, IT, cloud hosting, practice management and support services performed or provided in Australia, India, Vietnam, the Philippines and/or other jurisdictions notified to you or identified in CAAA’s privacy or outsourcing disclosures.

By accepting an engagement, you consent to CAAA using outsourced service providers, cloud computing providers and third party service providers as described in these Terms and any applicable privacy or outsourcing disclosure, subject to CAAA’s confidentiality, privacy, professional, supervision and quality management obligations. Where third party costs are not included in our fees, we may seek your approval before incurring material third party costs on your behalf.

10. Fees and billing

Fees

Our fees will be charged on the basis set out in the engagement letter, confirmation letter, fee proposal or fee schedule. Unless a fixed fee or other pricing arrangement is expressly agreed in writing, our fees are charged on a fee-for-service/time-cost basis by reference to the hourly rates of the CAAA personnel who perform or supervise the work and the time required to complete the assignment or task.

Unless expressly stated otherwise, all fees, hourly rates, fixed fees, estimates and disbursements are exclusive of GST. GST will be added where chargeable.
Our rates are reviewed from time to time and may be changed on notice to you. Updated rates apply to future work and continuing Services after notification, unless otherwise agreed in writing or stated in the engagement letter. If we provide an estimate, quote or fee range, it is an estimate only unless expressly stated to be a fixed fee. The actual fee may vary depending on the scope of work, complexity, urgency, quality of records, level of client assistance, third party involvement and any unforeseen matters.

Billing

We may issue interim, monthly or progress invoices at our discretion, including before a final invoice is rendered. Our credit terms are 14 days from the date of invoice unless otherwise agreed in writing or stated in the engagement letter.

We may require payment of your final balance before lodging tax returns, financial statements, ASIC forms or other deliverables. Where permitted and approved by you in writing, we may deduct our fee from your tax refund or from client monies in accordance with applicable law, professional standards and any trust account authority or written authority provided by you.

Payment may be made by EFT, direct debit, credit card or any other method accepted by CAAA. Payments by credit card or other payment services may attract a surcharge or service fee to the extent permitted by law. Dishonoured payments may attract applicable bank or administration charges.

If the engagement involves client monies or trust monies, we will deal with those funds in accordance with APES 310 Client Monies and only as authorised by you in a written Trust Account Authority Letter, written authority to deduct fees, or other written instruction accepted by us.

11. Interest and debt recovery costs for overdue invoices

Invoices that are overdue for more than 30 days may incur interest at a rate of 10% per annum, calculated daily and compounded monthly, on the overdue balance including GST and any interest previously accrued, to the extent permitted by law. We may reduce or waive interest at our discretion, including where a special payment arrangement has been approved in writing.

You agree to pay reasonable debt recovery costs and legal costs incurred by CAAA in recovering overdue amounts, to the extent permitted by law.

12. Joint and several liability for fees, costs and disbursements

Where more than one client is listed in an engagement letter, each client is jointly and severally liable for all fees, disbursements, interest, third party costs, debt recovery costs and other amounts payable under or in connection with the engagement, regardless of which client is invoiced or which client requested or received the relevant Services, unless CAAA expressly agrees otherwise in writing.

13. Ownership, documents, lien and record retention

You own original documents and materials provided by you. CAAA owns its working papers, file notes, methodologies, templates, know-how, internal records, calculations, checklists, review notes, drafts and other internal work product, whether in paper or electronic form.

Subject to payment of all outstanding fees and disbursements, you may use final work product prepared by CAAA for the purpose for which it was prepared. Unless we agree otherwise in writing, our work product must not be used, distributed or relied upon for any other purpose or by any third party.

Where permitted by law and professional standards, CAAA may exercise a lien over documents, records, work product or materials in our possession relating to any engagement for you until all outstanding fees, disbursements and approved third party costs are paid in full. Any dispute about a lien will be managed through CAAA’s dispute resolution process.

We will maintain records in accordance with applicable legal, regulatory and professional obligations. Tax agent and BAS service records will generally be retained for at least five years after the service is provided. AML/CTF records, where applicable, may be required to be retained for a longer period, including for at least seven years, depending on the nature of the record and the applicable law.

CAAA may store documents electronically and may scan and destroy hard-copy documents in accordance with its document management and retention practices, unless you have specifically requested in writing that original hard-copy documents be returned and we have agreed to retain them in hard-copy form.

14. Privacy

Our collection, use, storage and disclosure of personal information may be subject to the Privacy Act 1988 (Cth). We will collect personal information that is reasonably necessary for the Services and for related purposes, including client onboarding, identity verification, customer due diligence, tax, accounting, ASIC, payroll, superannuation, AML/CTF, sanctions, quality management, insurance, regulatory and record-keeping purposes.

We may collect personal information about you, your representatives, employees, directors, officers, trustees, beneficiaries, beneficial owners, clients, suppliers and other individuals connected with the Services. You must make all necessary notifications and obtain all necessary consents to provide that information to us and to allow us to use and disclose it for the purposes of providing the Services and complying with our legal, regulatory and professional obligations.

We may disclose personal information to third parties in Australia and overseas, including outsourced service providers, cloud computing providers, professional advisers, insurers, regulators and professional bodies, where reasonably necessary for the Services or required or authorised by law. Where we disclose personal information to an overseas recipient, we will take reasonable steps to ensure appropriate privacy, confidentiality and information security protections apply, subject to applicable law.

https://caaa.biz/privacy-policy/

15. Confidentiality

We have professional and ethical duties of confidentiality. We will take reasonable steps to keep your confidential information confidential, except where disclosure is permitted or required by law, regulation, professional standards, court order, client authority, our quality management processes, our insurers or professional advisers, or is reasonably necessary for providing the Services, using outsourced service providers or cloud computing providers, managing conflicts, responding to actual or suspected non-compliance with laws or regulations, AML/CTF or sanctions reporting, or participating in a professional body quality review or regulatory review.

Our duty of confidentiality continues after the engagement ends. You acknowledge that certain legal or regulatory obligations may require us to disclose information without notice to you, and in some circumstances we may be prohibited from notifying you of that disclosure.

We may use de-identified or aggregated information for internal training, quality management, benchmarking, product development or technology improvement, provided that you and your information are not reasonably identifiable from the output.

16. Communication and electronic communications

You must keep us informed of changes to your contact details. We may communicate with you using the last contact details you have provided to us, including by email, client portal, electronic signature platform, telephone, post or other electronic means.

Electronic communications can be affected by non-receipt, delay, interception, misdirection, cyber incidents, viruses and other risks. You are responsible for virus checking emails and attachments received by you. We are not responsible for communication failures or cyber risks outside our reasonable control.

Unless you instruct us otherwise, you consent to us communicating with you and relevant third parties electronically where appropriate.

17. Quality assurance and regulatory review

Your files, records and information may be subject to review under CAAA’s quality management system, by professional bodies, regulators, insurers, auditors of client monies, external reviewers or peer reviewers. By accepting an engagement, you acknowledge and consent to your engagement files being made available for these purposes, subject to applicable confidentiality, privacy and professional obligations.

18. Conflicts of interest

We will take reasonable steps to identify circumstances that may create a conflict of interest. We may act for more than one client or for related clients under an engagement where we consider it appropriate to do so and the relevant clients have a common interest.

If an actual or potential conflict arises, including between clients covered by the same engagement, we may need to disclose the conflict, obtain informed consent, implement safeguards, cease acting for one or more clients, or terminate the engagement. If your interests cease to align with another client covered by the engagement, you must notify us promptly.

19. Reliance on advice and third party use

Our advice, reports, documents and work product are provided only for the client(s) identified in the engagement and only for the purpose for which they are prepared. Unless we expressly agree in writing, no third party may use, rely on, reproduce, distribute or refer to our advice, reports, documents or work product.
If you provide our advice, reports, documents or work product to a third party without our prior written consent, you do so at your own risk and you remain responsible for any claim, loss, liability, cost or expense arising from that disclosure, use or reliance.

Verbal advice is not intended to be relied upon unless confirmed in writing. You must not rely on advice given on an earlier occasion without first confirming with us that the advice remains current and applicable to your circumstances.

20. Limitation of liability and indemnity

Limitation of liability

Our liability is limited by a scheme approved under Professional Standards Legislation.

To the maximum extent permitted by law:

1. any claim arising out of or in connection with an engagement, the Services, or any advice, report, document or work product provided by us, must be brought only against the CAAA contracting entity and not personally against any director, principal, shareholder, employee, contractor, consultant or related entity of CAAA. CAAA holds the benefit of this protection for itself and each of those persons;
2. CAAA is not liable for any indirect, special or consequential loss, loss of profit, loss of opportunity, loss of goodwill, or loss arising from inaccurate, incomplete or misleading information provided to us, your failure to provide timely instructions or information, use of our work product for a purpose other than that for which it was prepared, reliance by a third party without our written consent, the acts or omissions of third parties, or circumstances outside our reasonable control; and
3. CAAA’s liability will be reduced to the extent that any loss or damage is caused or contributed to by you, your representatives, another client covered by the engagement, or any third party.

Indemnity

You indemnify CAAA and its directors, principals, shareholders, employees, contractors, consultants and related entities against any loss, liability, cost or expense arising from your breach of the engagement, inaccurate or incomplete information provided to us, misuse or unauthorised disclosure of our advice or work product, or any claim by a third party who relies on our work without our written consent.

This indemnity does not apply to the extent the relevant loss, liability, cost or expense is caused by CAAA’s fraud, wilful misconduct or negligence.
Nothing in these Terms or any engagement letter excludes, restricts or modifies any right, remedy, guarantee, duty or liability that cannot lawfully be excluded, restricted or modified. This clause survives termination of the engagement.

21. Professional indemnity insurance

We hold professional indemnity insurance of at least the minimum amount prescribed by our applicable professional bodies, including CA ANZ, CPA Australia and/or IPA, and as otherwise required by law.

22. Termination and suspension

Either party may terminate an engagement by giving not less than 21 days’ written notice to the other party, unless a shorter period is agreed in writing or stated in the engagement letter.

CAAA may suspend or terminate an engagement immediately where permitted or required by law or professional standards, including where a conflict of interest arises, AML/CTF or sanctions concerns arise, client due diligence cannot be completed, you fail to provide instructions or information, you provide information that appears false or misleading, fees are overdue, or continuing to act would be unlawful, unethical or inappropriate.

Termination does not affect accrued rights or obligations, including your obligation to pay fees, disbursements, third party costs and expenses incurred up to the date of suspension or termination. Clauses concerning fees, confidentiality, privacy, ownership, lien, reliance, liability, indemnity, disputes, governing law and any accrued rights survive termination.

23. Disputes and complaints

If you have a concern about our Services, fees or conduct, please first raise it with the supervising director or client manager identified in the engagement letter. We may ask you to set out your complaint in writing so that it can be investigated and responded to appropriately.

CAAA will use reasonable endeavours to resolve complaints and disputes in a fair, timely and professional manner. If the complaint concerns a tax agent service or BAS service, you may also make a complaint to the TPB through the TPB complaints process.

24. Assignment, novation and business succession

You must not assign, novate or otherwise transfer your rights or obligations under an engagement without CAAA’s prior written consent. CAAA may assign or novate an engagement to a successor of the relevant CAAA business, a related entity or another CAAA group entity, provided that the successor assumes responsibility for the ongoing provision of Services.

25. Regulatory notices and demands

If we receive a legally enforceable notice, demand, subpoena, summons or request from a regulator, government agency, court, tribunal, professional body or other authority in relation to you or the Services, you agree to pay CAAA’s reasonable professional costs and expenses in complying with, responding to or challenging that notice or demand, to the extent those costs and expenses are not recovered or recoverable from the party issuing the notice or demand and to the extent permitted by law.

26. Force majeure

Neither party will be liable for any delay or failure to perform obligations to the extent the delay or failure is caused by events outside that party’s reasonable control, including natural disasters, fire, flood, pandemic, government action, war, terrorism, industrial action, cyber incidents, telecommunications failure, power failure, software platform outage, government portal outage or other events beyond reasonable control.

27. Governing law

The engagement is governed by the laws of New South Wales. The courts of New South Wales, and courts entitled to hear appeals from those courts, have non-exclusive jurisdiction in relation to any dispute arising out of or in connection with the engagement.

28. Application to CAAA entities

For the purposes of these Terms, CAAA means the CAAA contracting entity named in the engagement letter and, where the context requires, each of its related entities, and their respective directors, principals, shareholders, employees, contractors and consultants. Related entity has the meaning given by the Corporations Act 2001 (Cth), and includes any entity that becomes a related entity of the contracting entity after the date of these Terms. This definition applies to any CAAA group entity from time to time, whether or not it existed or was related when these Terms were issued.

29. Acceptance and continuing instructions

You accept these Terms by signing or accepting an engagement letter or confirmation letter that refers to these Terms, by instructing CAAA to proceed after receiving these Terms, by continuing to instruct CAAA after being notified of these Terms or any updated Terms, by providing information to us for the purpose of providing Services, or by accepting Services from us after notice of these Terms or any updated Terms.

For existing clients, continuing to request, instruct or accept Services after receiving notice of these Terms or updated Terms is taken as acceptance of those Terms for Services provided after the relevant effective date.