Verification confirmed
Health & Life
- Address
- 5/108 King William St, Adelaide SA 5000
- Phone
- 1800 077 222
- Website
- healthandlife.com.au (opens in a new tab)
Health & Life is a separate entity and is not part of Hamilton Bailey.
Hamilton Bailey
Payroll Tax 21 Requirements
PT21 framework v1.0, effective 10 August 2026
Client reference number:
Date:
Reviewed by:
For Accountants
Payroll Tax 21 Requirements
PT21 is Hamilton Bailey's own 21-point framework, built from the body of rulings and case law set out below and applied to each client matter.
We work with Australian accounting firms and software providers that support Facilities Service Providers and can review the financial and operational evidence relevant to the framework.
What PT21 Means
The 21 requirements we work through on every client matter
PT21 is Hamilton Bailey's shorthand for our own 21-point framework. We work through all 21 points on every client matter when reviewing a Facilities Service Provider arrangement. Most are financial and operational, which is why we work alongside the client's accountant rather than trying to cover that ground ourselves.
What the accountant covers
Most of the 21 requirements live in the books: how fees flow, how accounts are kept and reconciled, and how the arrangement is evidenced in the financial records. That is the accountant's work, not ours. We ask the client's accountant to confirm those requirements are met for the year.
What we cover
We review the Service Agreement and the legal structure of the arrangement, and we prepare the legal component of the file that supports the client's position.
Why both sides
A payroll tax arrangement is part legal structure and part financial reality. Neither of us can speak to the whole of it alone. Working with the client's accountant means the arrangement is properly evidenced on both sides before anything is put to a Revenue Office.
The 21 Requirements and Supporting Authority
Key areas assessed under Hamilton Bailey's PT21 framework, and the authorities they are assessed against
PT21 framework v1.0, effective 10 August 2026
The 21 requirements are assessed against the whole body of authority below, not mapped to individual numbered requirements. The interaction of these rulings and decisions is why each client matter is worked through individually.
1
Valid and binding Service Agreement in place2
Clear delineation of independent contractor status3
Arm's-length fee arrangements documented4
Operational independence demonstrated5
Separate ABN registration verified6
Professional indemnity insurance held by practitioner7
Control over work methods retained by practitioner8
Equipment and tools ownership clarified9
Risk of profit/loss borne by practitioner10
Right to delegate or subcontract11
Ability to work for other Facilities Service Providers12
No exclusivity clauses (unless commercially justified)13
Billing arrangements properly structured14
Patient records ownership defined15
Marketing and branding separation16
Leave and entitlements not provided (as employee would receive)17
Superannuation arrangements compliant18
GST registration and treatment19
Medicare billing compliant20
Privacy Act compliance documented21
Further requirements disclosed in consultationNote: Further requirements may be disclosed in consultation. Their substance is not published on this page in the interest of brevity, and can be discussed with interested parties.
Authorities current as at 9 August 2026. Revenue rulings are amended from time to time. This table is general information only and is not a substitute for current advice on a specific arrangement.
Some authorities are not linked because a stable public URL could not be confirmed.
Verified Accounting Firms
Firms that have confirmed they can evidence the 21 requirements.
- 1
- 2
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To be announced upon positive verification
- 3
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To be announced upon positive verification
For Accounting Firms and Software Providers
Applications are open to accounting firms and software providers that can evidence the 21 requirements, including reconciliation.
Evidence-led Client Service
Provide clients with evidence-led payroll tax compliance services
Clear Process
Established workflow for the PT21 review and the annual client review
Grounded in Current Authority
Work anchored to the current rulings and decisions set out on this page
Related Information
Learn more about Facilities Service Provider compliance
Interested in Working With Us?
If you can evidence the 21 requirements for our joint clients, we'd love to hear from you.
Are You a Medical Sector Accountant?
Call us
(08) 5122 6500
Email us
accountants@hamiltonbailey.com
Response time
Within 72 hours