1. 30-10(1) - You must act honestly and with integrity
2. 30-10(5) - You must have in place adequate arrangements for the management of conflicts of interest that may arise in relation to the activities that you undertake in the capacity of a registered tax agent or BAS agent

On 28 July 2025, after completing an investigation, the Tax Practitioners Board (TPB) decided to terminate the tax agent registration of Thomas Seymour (Mr Seymour) and impose an exclusion period of four (4) years. The TPB determined that Mr Seymour, who held a senior leadership position within PwC, had breached the Code of Professional Conduct (Code) in the Tax Agent Services Act 2009 (TASA) relating to integrity and managing conflicts of interest (subsections 30-10(1) and 30-10(5) of the TASA).

The TPB made the findings that Mr Seymour failed to act with integrity and failed to have in place adequate arrangements to manage conflicts of interest that arose in relation to activities undertaken by partners and employees within PwC’s Tax & Legal services division, when he held the position of Managing Partner, PricewaterhouseCoopers (PwC) Tax & Legal from July 2012 to June 2016 and Managing Partner, Financial Advisory & Asia Pacific Americas Tax Leader from July 2016 to April 2020 in that he;
1. was notified on 10 December 2013 and 11 December 2013 that Peter Collins (Mr Collins) and another PwC Partner would be consulting with Treasury as part of the Base Erosion Profit Shifting (BEPS) Tax Advisory Group, with other PwC partners subsequently being engaged in other confidential Treasury consultation groups and meetings during the 2013 to 2017 time period;
2. was accountable and responsible for the conduct and procedures of the Tax & Legal services division, with partners, including Mr Collins, reporting either directly or indirectly to him;
3. failed to take any action, or otherwise implement any procedures, to ensure that the actual conflicts of interest which arose for individual partners in the PwC Tax & Legal services division, as well as for PwC as a registered tax agent firm, were appropriately managed;
4. failed to recognise, or otherwise permitted, a business culture to develop and operate within the Tax & Legal services division at PwC whilst he was the Managing Partner that included unethical and improper professional conduct by multiple partners within the area, which resulted in:
a) confidential information obtained by PwC partners engaged in Treasury consultations being shared with PwC partners and employees, both within Australia and overseas, for the purpose of assisting PwC to position itself ahead of its competitors, advance its position in the market and to expand its client base;
b) the practice of sharing confidential information, or ‘intelligence’, being widespread within the Tax & Legal services division despite regular and repeated references from PwC partners to the information being ‘confidential’ and that it should not be disclosed, suggesting a broad cultural acceptance for this type of behaviour and conduct;
5. personally received several items of email correspondence between August 2014 and January 2016, the content of which should have raised questions about the source of information being disclosed within PwC’s Tax & Legal services division, and whether such information was being appropriately shared within that division, and the receipt of which should also have resulted in Mr Seymour escalating or otherwise making enquiries in respect of how confidential information was being managed within the division.
6. did not take action in relation to the way in which confidential information was shared within PwC’s Tax & Legal Division.

The TPB also found that Mr Seymour failed to have adequate arrangements in place to manage conflicts of interest that arose in relation to activities undertaken by partners and employees within PwC’s Tax & Legal services division, when:
1. the partners of PwC, including but not limited to Mr Collins, who were engaged by Treasury in confidential consultations continued to provide tax agent services to clients of PwC that would be affected by the proposed Australian tax legislation and policy positions intended to give effect to the Organisation for Economic Co-operation and Development’s (OECD) BEPS provisions, including the Multinational Anti-Avoidance Law (MAAL), Diverted Profits Tax (DPT) and Hybrid mismatch rules;
2. the information obtained by PwC partners engaged in confidential Treasury consultations was shared amongst other PwC partners and employees, both within Australia and overseas, for the purpose of assisting PwC to position itself ahead of its competitors, advance its position in the market and to expand its client base;
3. the sharing of this confidential information, or ‘intelligence’, was widespread within the Tax & Legal services division, despite regular and repeated references from PwC partners in email correspondence to the shared information being ‘confidential’ and requesting that it should not be disclosed further, which suggests a broad cultural acceptance for disregarding formal confidentiality obligations attaching to information
in circumstances where, in the absence of adequate procedures being implemented to manage conflicts of interest, PwC partners utilised confidential information they received from other PwC partners, including Mr Collins, to inappropriately design and market tax advice to current and potential clients for the benefit of PwC.

Having regard to the seniority of Mr Seymour’s position within PwC, and his responsibility for supervision of senior partners within the firm and over the culture of the firm, the seriousness of his conduct, and the need for public deterrence the TPB determined that:
1. Mr Seymour’s tax agent registration should be terminated for his breaches of the Code; and
2. Mr Seymour be prohibited from applying for registration as a tax agent for four years from the date the termination of his registration takes effect.