Coronavirus Job Retention Scheme – enhanced guidance as at 15 April 2020

HMRC have issued a third set of guidance for employers on how the Coronavirus Job Retention Scheme (CJRS) will operate, including some changes to the previously released eligibility criteria. Highlighted below are some of the important points, including some changes from previous announcements.

The information provided in this article is based on the details available at 15 April 2020.

Has there been any change to who can claim?

Previously, HMRC announced that an employer must have created and started to operate a PAYE payroll scheme by 28 February 2020. This has been amended to 19 March 2020.

You can only claim for furloughed employees who were on your PAYE payroll scheme on or before 19 March 2020 and who were notified to HMRC on an RTI submission on or before that date. This means an RTI submission notifying payment in respect of that employee must have been made to HMRC on or before 19 March 2020.

Employees who were employed as of 28 February 2020 and included on a RTI submission to HMRC on or before 28 February and were then made redundant or stopped working for the employer after that date, but prior to 19 March 2020, can also qualify for the scheme if the employer re-employs them and puts them on furlough.

When is the portal expected to go live?

The government has announced that the portal, through which claims will be submitted, will be available from 20 April 2020.

What information will be required to support a claim?

To claim, you will need:

  • your employer PAYE reference number;
  • the number of employees being furloughed;
  • National Insurance numbers for the furloughed employees;
  • names of the furloughed employees;
  • payroll/employee numbers for the furloughed employees (optional);
  • your Self-Assessment Unique Taxpayer Reference (if the employer is a self-employed individual or partnership), Corporation Tax Unique Taxpayer Reference or Company Registration Number;
  • the claim period (start and end date);
  • amount claimed
  • your bank account number and sort code;
  • your contact name and your phone number.

It should also be noted that, if you have less than 100 furloughed staff, you will simply be asked to enter details of each employee you are claiming for directly into the portal (details as referred to above), however, if you have 100 or more furloughed staff you will be required to provide the necessary information via an upload file (e.g. a .csv).

Do we know when HMRC will release the grant funds?

We understand that HMRC hopes to make the first payments by 30 April. For future claims, they expect to pay employers within 6 working days of the claim being submitted.

How does CJRS interact with sick pay?

The CJRS is not intended for short-term absences due to sickness or self-isolation, but an employee may be moved from sick pay to furlough pay if there are business reasons for doing so.

Employees who are shielding or who are on long term sick leave can be furloughed with the grant being claimed, but the decision on whether to do this rests with the employer; an employee cannot demand to be furloughed.

Employees who become sick while on furlough can be kept on furlough pay, but must be paid at least SSP

Employers can claim from both the CJRS and the SSP rebate scheme for the same employee, but not for the same period of time

What if employees are transferred between group companies?

If a group of companies transfers employees from multiple PAYE schemes into a new consolidated PAYE scheme after 28 February 2020, the new scheme will qualify for the CJRS.

Has the government provided any further guidance surrounding holiday pay whilst on furlough?

No, we are yet to receive clarification on this, but it is hoped that further guidance will be released shortly.

Will HMRC provide any support to businesses in respect of the claim calculations?

It has been announced that HMRC will be providing a downloadable spreadsheet to assist with the calculations which professional bodies are encouraging businesses to use. These calculations must be retained by the employer for five years.

Other sources of help in relation to furloughing

Our clients who have taken out Tax Compliance Service cover in relation to tax enquiries have access to a dedicated HR Helpline; if you would like any further information about accessing this, please let us know.

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