Explanatory Note

The Department’s view is that preparing and filing a client’s tax return as part of a tax accounting service is not ordinarily covered by the AML/CFT Act. However, in some circumstances, involvement by an accounting practice in any associated tax transfers, payments and/or refunds will be captured by the AML/CFT Act. The activities in the AML/CFT Act that are most likely to be relevant in this context are: • Managing client funds, accounts, securities or other assets (paragraph (a)(iv) of the definition of designated non-financial business or profession (DNFBP)); • Engaging in or giving instructions for a transaction on behalf of a customer in relation to creating, operating, and managing a legal person or other legal arrangement (paragraph (a)(vi)(E) of the definition of DNFBP) (engaging in/giving instructions).