1. 30-10(1) - You must act honestly and with integrity
2. 30-10(4) - You must act lawfully in the best interests of your client
3. 30-10(7) - You must ensure that a tax agent service that you provide, or that is provided on your behalf, is provided competently
4. 30-10(9) - You must take reasonable care in ascertaining a client's state of affairs, to the extent that ascertaining the state of those affairs is relevant to a statement you are making or a thing you are doing on behalf of the client
5. 30-10(10) - You must take reasonable care to ensure that taxation laws are applied correctly to the circumstances in relation to which you are providing advice to a client
6. 20-5(1)(a) Individual has ceased to meet registration requirement that they are a fit and proper person

On 27 June 2025, after completing an investigation, the Tax Practitioners Board (TPB) decided to terminate the tax agent registration of Mr Richard Gregg as he ceased to meet the tax practitioner registration requirement that he be a fit and proper person.

The TPB found that Mr Gregg was no longer a fit and proper person on the basis that he, in his capacity as a partner for PricewaterhouseCoopers (PwC):

1) had engaged in conduct that breached subsections 30-10(1)(honesty and integrity), 30-10(4)(acting lawfully in the best interests of client), 30-10(7)(competence), 30-10(9) and 30-10(10)(taking reasonable care) of the Code of Professional Conduct (the Code) in the Tax Agent Services Act 2009 (TASA);

2) had demonstrated that he was not of good fame, integrity and character by:
a) engaging in dishonest conduct by knowingly making statements in declarations on Research & Development Tax Incentive (RDTI) applications lodged on behalf of multiple clients that he knew, or ought to have known, were false;
b) making those RDTI claims in circumstances where the conduct of lodging the claims without making proper enquiries of the clients’ circumstances can be explained as being motivated by the pursuit of a personal advantage in the form of an increase in revenue for PwC’s Research & Development (R&D) tax incentive group (of which he was the leader); and
c) providing tax agent services, as the partner responsible for RDTI applications for multiple clients in a careless, negligent and incompetent manner given:
i) the technical nature of R&D matters and therefore the reliance of clients on the expert advice of Mr Gregg and his supervised staff in relation to their applications;
ii) the significant monetary amount of the claims and resulting tax shortfalls and penalties that accrued to the clients; and
iii) the time and resources expended by the Commissioner of Taxation (Commissioner) and Industry Innovation and Science Australia to assess the RDTI applications of those entities in circumstances where those applications could not be supported by evidence.

The TPB considered that Mr Gregg’s conduct demonstrated a lack of integrity and negligence, and that he failed to show any reasonable level of acknowledgement or contrition for his conduct.

The ATO determined that the clients affected by Mr Gregg’s conduct had a cumulative tax shortfall of over $11 million, and imposed cumulative penalties of over $800,000 across those clients.

The TPB found that Mr Gregg had engaged in conduct that breached the Code by:

1) making false or misleading statements in applications for the RDTI for multiple clients when he completed declarations when he knew, or ought to have known, that the information in those applications:
a) did not support claims for the RDTI (including because some applications provided the exact same information as that provided in another client’s application);
b) was not supported by satisfactory evidence showing that the respective entities for which he was acting as R&D consultant undertook core or supporting R&D activities and/or could substantiate the conduct of those activities;

2) as the PwC partner responsible for RDTI claims for certain clients, acted with such carelessness as to demonstrate that no genuine attempt has been made to carry out his duties and obligations under the law in circumstances where the RDTI claimants were wholly reliant on his expert R&D advice;

3) failing to identify that the evidence of payments relating to an entity, which were included in RDTI claims for a client, were not related to R&D activity; and

4) providing advice, or causing his staff to provide advice, in regard to activities undertaken by clients that were relevant to the preparation of their RDTI claims, when:
a) he had no direct knowledge, and did not attempt to obtain knowledge, of the activities being claimed as R&D activities; and
b) the Commissioner determined that the activities were not core or supporting activities for the purposes of the RDTI.

Taking into account the seriousness of Mr Gregg’s conduct, the TPB also determined that Mr Gregg should be prohibited from applying for registration for a period of four years from the date the termination of his registration takes effect.