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. 20-5(3)(a) Company has ceased to meet registration requirement that each director is a fit and proper person

On 11 September 2025, after completing an investigation, the Tax Practitioners Board (TPB) decided to terminate the tax agent registration of Coolah Tax & Accounting Pty Ltd (the Company). The TPB found that the Company had breached subsections 30-10(1), 30-10(4) and 30-10(7) of the Code of Professional Conduct (the Code) in the Tax Agent Services Act 2009 (TASA) and had ceased to meet the registration requirement under paragraph 20-5(3)(a) of the TASA that each director of the Company must be a fit and proper person. The TPB made this decision on the basis of its finding that the Company’s sole director, Mr Denis Yeo, was no longer a fit and proper person.

The TPB found that the Company breached the Code by failing to have adequate supervision and control measures in place to ensure that tax agent services provided on its behalf by Mr Randolf Rindfleish were provided competently and in accordance with the applicable taxation and other laws.

The Company’s failure to supervise and control the activities of Mr Rindfleish, enabled him to misappropriate almost $150,000 from 22 clients between 3 April 2023 and 22 September 2023 by lodging business activity statements on behalf of those clients under the Company’s tax agent registration number, and then directing the resulting refunds into bank accounts he controlled.

The TPB also determined that Mr Yeo, as the Company’s sole director, had ceased to meet the tax agent registration requirement under paragraph 20-5(1)(a) that he must be a fit and proper person, on the basis that he:
1. engaged in conduct that breached subsection 30-10(7) of the Code in the TASA.
2. in his capacity as a director and supervising agent of company tax agent Wollongong Business Accountants Pty Ltd, similarly failed to supervise tax agent services provided on behalf of that company, enabling Randolf Rindfleish to misappropriate more than $750,000 from 49 separate clients between 2 July 2020 and 27 March 2023.
3. demonstrated a pattern of behaviour of failing to meet his obligations as the supervising agent for a registered company tax agent.
4. failed to have adequate oversight in his capacity as director and supervising agent to prevent the misappropriation of client ATO refunds by Randolf Rindfleish resulting in significant adverse impacts on those clients.
5. engaged in conduct that:
a. undermines the integrity of the taxation system and the professional standards expected of tax practitioners.
b. is of such seriousness that the TPB, Commissioner, clients and the public could not have confidence that Denis Yeo would perform his functions as a registered agent to the required standard of integrity and competence.
6. demonstrated a pattern of behaviour of failing to meet his obligations as supervising agent for two different registered company tax agents.
7. failed to maintain adequate oversight of the activities of those company tax agents in his capacity as director and supervising agent leading to a failure to prevent or detect the misappropriation of client ATO refunds by Randolf Rindfleish, resulting in significant adverse impacts on those clients.
8. engaged in conduct of such seriousness that the TPB, the Commissioner of Taxation, his clients and the general public could not be confident of Mr Yeo’s ability to perform his functions as a registered tax agent with integrity and competence, thereby undermining the integrity of the taxation system and the professional standards of the tax profession.

The TPB acknowledged Mr Yeo’s cooperation and engagement throughout the investigation, and his demonstration of genuine remorse for his failure to adequately supervise Randolf Rindfleish. The TPB considered that this shortfall in supervision and control enabled a malign actor to take advantage of the privileged role of tax practitioners within the tax system for personal gain. The TPB acknowledged that this had caused real and potentially lasting damage to the trusting clients of the Company who were targeted by Mr Rindfleish.

The TPB decided that it was appropriate in these circumstances to terminate the Company’s tax agent registration pursuant to paragraph 40-15(1)(b) of the TASA. The TPB also decided to impose a period of three years from the date the termination of the Company’s registration takes effect during which the Company is prohibited from applying for registration, pursuant to subsection 40-25(1) of the TASA.

The TPB considered that it must take a very firm approach in cases of this nature to send a clear message to the practitioner community that failing to do the right thing and adhere to the Code, including ensuring the compliance of entities under the supervision of registered practitioners, will not be tolerated. The TPB considers that the effectiveness of, and public confidence in, the tax system relies heavily on registered practitioners being alert to the type of conduct engaged in by Mr Rindfleish and failure prevent such conduct can damage public trust in the integrity of the system.