Nathan Trust Insights

Temporary Wage Subsidy Scheme COVID-19

Written by Rory | Feb 2, 2022 12:28:27 PM

The Irish Government has announced a number of schemes to provide financial support to Irish employers and employees who have been impacted by the COVID-19 pandemic. One such scheme is the Temporary COVID-19 Wage Subsidy Scheme. This scheme replaces the Employer Refund Scheme.  

 

Update: Revenue announces access to the Temporary COVID-19 Wage Subsidy Scheme for certain employers who missed the 15 March payroll deadline

Certain employers who had not fulfilled their PAYE reporting obligations for February 2020 by 15 March 2020 will be allowed to access the Temporary Wage Subsidy Scheme.

Revenue has allowed certain employers to access the Scheme provided:

  • The employees in question were included on the employer’s payroll on 29 February 2020.
  • The February 2020 payroll submission was submitted to Revenue before 1 April 2020.
  • Payroll submissions for all previous months were submitted to Revenue before 15 March 2020.

Where employers want to avail of Temporary Wage Subsidy Scheme payments, they should ensure that eligible employees are set to J9 PRSI class on future payroll submissions.

Any employees that were laid off after 29 February 2020 can be placed back onto the payroll for the purposes of the Scheme. In the event where employees are receiving COVID-19 related Pandemic Unemployment Payments (PUP) from the Department of Employment and Social Protection (DEASP), then they are subsequently rehired by their employer to avail of the Temporary Wage Subsidy Scheme payment should cease their PUP claim.

Revenue and DEASP are working together to identify duplicate payments.

Additional updates:

  • The employer does not have to cease employment for an employee to be able to receive the COVID-19 Pandemic Unemployment Payment (PUP). However, if an employee is receiving both the PUP and a subsidy under the TWSS, DEASP will cease their PUP payments.
  • Confirmation that from 16 April 2020, the wage subsidy is available to support employees whose ARNWP was greater than €960 and their current gross pay is below €960 per week, subject to the tiered arrangements and tapering.
  • Information on how the Department of Children and Youth Affairs (DCYA) Wage Subsidy Childcare Scheme (WSCS) will operate from 20 April 2020 to 3 May 2020, with examples on the calculation for the DCYA WSCS. 

We recently held a webinar to discuss this topic with Accounts Mark Nathan and David Bruton.

You can watch the webinar here on our Youtube channel:

What is the Temporary COVID-19 Wage Subsidy Scheme?  

The Temporary COVID-19 Wage Subsidy Scheme allows employees affected by the crisis to receive funds directly from their employer, with the employer being subsidized by the Government.  

How much will each employee receive? 

The Temporary COVID-19 Wage Subsidy Scheme will refund employers up to a maximum of €410 for each eligible employee.  

How long will the Temporary COVID-19 Wage Subsidy Scheme operate? 

Commencing this Thursday 26 March 2020, the Temporary COVID-19 Wage Subsidy Scheme is expected to last for 12 weeks.  

Who can apply to the Temporary COVID-19 Wage Subsidy Scheme? 

The Temporary COVID-19 Wage Subsidy Scheme is available to employers whose business activities are being impacted by the COVID-19 pandemic. 
Businesses/Employers from the public service and non-commercial semi-state sector cannot apply. 
 
The Temporary COVID-19 Wage Subsidy Scheme is restricted to employees whose payroll submission has been made to Revenue during the period from 1 February 2020 to 15 March 2020. Subsidies for employees that were taken off the payroll since 15 March can be arranged once they were included in the Employer's February payroll submissions between 1 February 2020 and 15 March 2020 under the same PPSN number.

UPDATE:

Specified Employees 

The Act provides that specified employees in relation to an employer are defined as an individual who was on the payroll of the employer as of 29 February 2020. In addition, employers should meet the two following conditions:

  • a notification or notifications of the payment of emoluments to the employee in February 2020 in accordance with Regulation 10 of the Regulations by the employer was submitted to the Revenue Commissioners;
  • The monthly return has been submitted by the employer, along with details of tax deducted for the month of February 2020 on or before 15 March 2020. Please note: The payment of the tax does not have to have been made.

The requirement that employees were on the payroll for February stands, and will not be relaxed according to Revenue. 
 

To qualify for the scheme, employers must: 
 
1. Be experiencing significant negative economic disruption due to the COVID-19 pandemic 

2. Be able to establish and prove there is a minimum of a 25% decline in turnover

3. Be unable to pay regular employee wages and normal outgoings in full

UPDATE:

  • the impact on turnover can be based on the best estimates for the quarter made by the employer;
  • employers can assess the impact on the turnover on a divisional basis where the overall turnover of the employer is not impacted to the required level. 
  • employers with cash reserves that were held for investment, expansion, or repayment of debt are eligible to participate in the Scheme. Employers whose cash reserves are not earmarked for investment, expansion or repayment of debt can still participate in the Scheme, however, it would be expected of them to top-up employee wages to the average weekly net pay level;
  • Revenue will engage with employers whose turnover may not drop by 25% in Quarter 2, but who have suffered reductions in orders due to the COVID-19 pandemic, and where future turnover might be impacted in subsequent quarters;
  • overall group turnover impacts can be used where this entitles an employer to participate in the Scheme. Engagement with Revenue on this would be required to ensure compliance; and
  • in relation to Start-up companies, Revenue is prepared to be flexible in its assessment of the impact on turnover.

Revenue is operating the scheme flexibly. They are seeking not to be prescriptive, but rather agile in dealing with the different circumstances employers are facing.

 
How does the Temporary COVID-19 Wage Subsidy Scheme work? 


Employers use their normal payroll process to make support payments to their employees. 

Employers will then be reimbursed for the amounts paid to their employees and notified to Revenue through the payroll process. 

Employers can expect the reimbursement within two working days after receipt of the payroll submission. 

In April, the scheme will move to a subsidy payment based on 70% of the weekly average take-home pay for each employee up to a maximum of €410

Income tax and USC will not be applied to the subsidy payment through the payroll. 

Employee PRSI will not apply to the subsidy or any top-up payment by the employer. 

Employers PRSI will not apply to the subsidy and will be reduced from 10.5% to 0.5% on the top-up payment. 

UPDATE

Wage Subsidy - Clarifications

The wage subsidy potentially payable is as follows:

  • it cannot exceed 70% of the net pay that would have been payable. Where the net pay (were it not for the COVID-19 emergency) payable was not more than €586 per week, an amount not exceeding 70% of the net weekly emoluments.  This is not the same thing as €410 as if the net pay per week was €500, then the subsidy will be €350;
  • where the net pay (were it not for the COVID-19 emergency) payable was more than €586 per week but not more than €960 per week, an amount to be determined by the Minister for Finance (this is €350 per week); and
  • where the net pay is in excess of €960 per week, there is no subsidy. 


Declaration 

All employers wishing to apply to the Scheme must make the following declaration: 
 
In accordance with the legislation governing the Scheme, I declare to the Revenue Commissioners that the business intends to operate the COVID-19: Temporary Wage Subsidy Scheme and I confirm that the business is experiencing significant negative economic disruption due to COVID-19, and can demonstrate, to the satisfaction of Revenue, that the negative disruption is leading to a minimum of 25% decline in actual or predicted turnover, an inability to pay normal wages and outgoings and, to other circumstances as set out in published Revenue Guidelines. 

I accept the conditions of the Subsidy Scheme, that (i) the business will retain its employees on its payroll, (ii) any payments made to the business in excess of 70% of the net weekly pay of each employee will be repaid by the business to Revenue as quickly as possible or will be offset by Revenue against future payments arising under the Scheme, (iii) any abuse of the scheme that comes to light following a Revenue compliance intervention into the operation of the Subsidy Scheme will be subject to significant penalties. 

Penalties 

Penalties will apply to any abuse of the Subsidy Scheme by self-declaring incorrectly, not providing funds to employees or non-adherence to Revenue, and any other relevant, guidelines. 
 
The Temporary COVID-19 Wage Subsidy Scheme should only be used by companies that need it. Revenue will most likely conduct a thorough follow-up on all companies that avail of this Scheme.   

Revenue and the Department of Employment Affairs and Social Protection (DEASP) will be checking the eligibility of employers and employees for this scheme. Checks will include:

1. That the employer has applied to operate the scheme,
2. That all eligible employees are included on a payroll submission made by the employer in the period from 1 February 2020 to 15 March 2020,
3. That the eligible employee was on the payroll as of 29 February,
4. That the employer has paid the full subsidy amount to the employee, and
5. Those employees have not received the wage subsidy from multiple employers or have not received a payment from DEASP.

If you need help applying for the Temporary COVID-19 Wage Subsidy Scheme you can contact us using the form below: