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SMPAG Response to the IESBA Exposure Draft of Proposed Revisions to the Code Addressing Tax Planning and Related Services

| Comment Letters

The IFAC Small- and Medium- Practices Advisory Group (SMPAG) welcomes the opportunity to provide input to the International Ethics Standards Board for Accountants (IESBA) Exposure Draft on the proposed revisions to the Code addressing tax planning and related services.

The SMPAG agrees that Professional Accountants (PAs) should behave ethically in all their work and acknowledges that the fundamental principles of the IESBA Code already apply to taxation related services or activities but have challenged the breadth of activities that will fall in scope of the changes as this may have a disproportionate impact on SMPs. The proposed revisions will also require PAs to make judgements in several areas including identifying the public interest, assessing whether arrangements have a "credible basis in laws and regulations" and determining the perspectives of varied stakeholders. Judgments in such highly subjective areas could be challenging and time consuming but would often add little value where arrangements in question are routine. The broad scope in line with the encouragement to produce documentation could also create extra work for PAs on these routine engagements which could be detrimental to their ability to compete with others who operate in this space, including unregulated actors.

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