An annual tax engagement can acquire a different purpose in a short conversation. The client who originally wanted accounts prepared may later ask the practice to implement a new company or coordinate a transaction. The useful control is a dated scope-change record tied to the new instructions. It helps the team decide what work can proceed and what needs assessment before implementation starts.
Describe the changed work in ordinary language
Compare the original deliverable with the newly requested acts. Write who will prepare documents, deal with counterparties, lodge applications, control funds or give implementation instructions. A job code such as advisory does not explain those acts. Record what the practice has already done, what remains proposed and when the change became known. Keep the original engagement description so the history remains intelligible.
Make a fresh service decision
Test the actual work against the applicable designated service and Australian geographical link. AUSTRAC's professional-services guidance distinguishes active work that directly advances a specified outcome from advice that merely influences a decision. An accountant's title does not answer that question. Identify the relevant item, factual reasons and any uncertain boundary requiring advice. Where the conclusion is outside scope, describe the facts that would require reconsideration.
Use a changed-instructions example
Suppose a client first asks about the tax consequences of different structures, then requests preparation and lodgement of company-creation documents. Keep those two stages separate in the record. Identify the instructing person and the service's customer population under the relevant item; do not simply copy the tax client's name into every role. Assign the applicable CDD and program checks before the newly captured work begins, subject to any lawful exception.
Hand the decision to the person doing the work
Give the responsible staff member a short instruction: service assessed, work permitted, unresolved checks, decision owner and next review trigger. Link the supporting engagement email and assessment rather than relying on an informal message. If another team changes the proposed structure again, reopen the decision. Completion of one scope review should not hide later changes in parties, money flows or the purpose of the work.
Official sources
Confirm the current rules against these primary sources, last checked .
Questions
Does a changed engagement always become designated?
No. Review the new acts against the service definition. A larger fee, urgent request or advisory label is not itself the statutory trigger.
Should the original assessment be overwritten?
Preserve it and add a dated revision. A reviewer should be able to distinguish the information available at each decision.
Who resolves an uncertain boundary?
Use the escalation route in your program and obtain qualified advice where needed before relying on an unresolved classification.
General information for Australian professionals, not legal advice. It does not replace the AML/CTF Act, the Rules or AUSTRAC guidance. See our editorial standards.
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