Revenue are currently undertaking a programme of compliance checks on all employers that are accessing, or have accessed, the Temporary Wage Subsidy Scheme (TWSS).
What to expect during the compliance checks
A letter will be issued to employers and their agents, where relevant, through ROS MyEnquiries. The letter will set out the steps employers need to take to verify their compliance with the regulations of the TWSS.
Employers will be asked to confirm that:
- They meet the eligibility criteria,
- Their employees are receiving the correct amount of subsidy, and
- The subsidy amount is being correctly recorded in employees’ payslips.
As part of the verification process, Revenue will request the following information from all employers:
- An outline of the nature of the business and its principal activities,
- A summary statement outlining the impact the Covid-19 pandemic has had on the business (see below on what should be included)
- Confirmation that payslips were issued to all employees for the pay periods the subsidy payments were received,
- A list of all employees in receipt of the TWSS, and
- A copy of the following payslips for each employee listed:
- The last J9 Payslips issued before 04 May 2020, and
- The most recent J9 payslip.
As part of the summary statement in response to Revenue, employers must include the following information:
- The date the business closed or was first impacted by the crisis,
- Details of the basis used for estimating a 25% reduction in turnover or customer orders. If an alternative basis was used to determine eligibility please describe same,
- The number of employees retained. If any employees were not retained, please list the number of employees laid off and the reason(s) for their non-retention, and
- Any adjustment to the director’s salary since the start of 2020.
If Revenue reasons that the employer failed to meet the eligibility criteria, any subsidy payments received by the employer must be repaid.
Monitor your ROS MyEnquiries inbox
Going forward, it is essential that the ROS MyEnquiries inbox is monitored on a regular basis. Employers are obliged to submit the requested information to Revenue via ROS MyEnquiries within 5 working days from the date listed on the letter. Failure to do so will lead to the suspension or delay of future subsidy payments.
An opportunity to get accounts in order
As these compliance checks are expected to last for several months, all employers need to ensure that the required information is up-to-date. These checks also provide an opportunity for employers to address any issues related to the PAYE Modernisation and any outstanding tax issues. This opportunity will be especially advantageous to any employers who intend on availing of the “debt warehousing” arrangement as the timely filing of returns is a qualifying condition of the scheme.
If you have any questions about the TWSS Revenue Compliance Checks or how to make sure your accounts are in order, contact us today on 021 486 1486 or email us at info@mc2group.ie.