“You need to be acutely aware of the time frames with reporting even with your annual clients because it might not just be default 15 May each and every year,” Mr Dunn said.

“Therefore, if you’re thinking about when you might lodge that information to the ATO, it may still be prudent to line that up with the tax return of the fund next year.

“For some practices, they have just made a conscious decision to bring everyone into that time frame; otherwise, there is a greater level of segmentation that you are going to need to do in your practice to ensure you can marry up and meet those ongoing requirements between your different clients.”

While Mr Dunn noted that the ATO is currently working with the profession to bed down the changes, practitioners should be aware that an attitude shift will occur in the future.

“At some point, the ATO will flick the switch from education to enforcement. We know that is the case — we look at collectibles as an example and the five-year period we had to deal with those sorts of things,” Mr Dunn said.

“If we have multiple events that have not been lodged on time, this penalty could become quite significant, so [make] sure that you understand this scope of work that you are doing with your clients, and that they understand your responsibilities. 

“How many of you have updated your engagement letter with your clients to look at who is responsible in respect to the events based reporting with the fund? If you haven’t, I would suggest that you do that — work out is it your responsibility, is it your client’s responsibility or is it a shared responsibility.

“The ATO for the current year is taking a very judicious approach, but the shift will happen, so be forewarned.”