The COVID-19 Temporary Wage Subsidy Scheme came into effect on 26 March 2020. The scheme allows eligible employers to continue to pay their qualifying employees during the COVID-19 pandemic. The objective of the scheme is to keep employers registered with their employers, facilitating a quick return to work after the pandemic has passed. The scheme is available to employers who wish to top up employee payments and those who are not in a position to do so. Employers who have not already registered for the scheme can apply via ROS My-Enquiries.
To qualify for the scheme, employers must:
- be experiencing significant negative economic disruption due to COVID-19,
- be able to demonstrate, to the satisfaction of Revenue, a minimum of a 25% decline in turnover,
- be unable to pay normal wages and normal outgoings fully, and
- retain their employees on the payroll.
Notwithstanding the existence of the current crisis employers should only apply for the scheme if it is their firm intention to continue to employ the specified employees and make best endeavours to pay their staff their normal salaries. The scheme will operate under the principles of self -assessment however, Revenue will be undertaking reviews to ensure the scheme is not being claimed by ineligible employers. Therefore, if a company does not have a genuine intention of making a top-up payment, then we would advise employers not to apply for the scheme.
The scheme applies to employees:
- who were on the employer’s payroll system as at 29 February 2020, and for whom a payroll submission was made in the period 1 February to 15 March 2020.
- who have an average net salary of less than €960 per week (Gross annual salary of €76,000)
- who have been laid off and subsequently rehired, provided they were on the payroll between 1 February and 15 March 2020 and are not in receipt of the separate DEASP, Unemployment Pandemic Payment.
- who were on a reduced working week or a reduced salary.
In accordance with the provisions of the scheme, employers can pay up to 70% of the employee’s net pay, as a non-taxable payment and receive a refund from Revenue. The refunds will be capped at:
- €410 if the employee’s average net weekly salary is less than €586 (Circa Gross Salary of €38,000 p.a), or
- €350 if the employees average net weekly salary is greater than €586 (Circa Gross Salary of €38,000 p.a) but less than or equal to €960 (Circa Gross Salary of €74,000 p.a)
The refund should be processed to the employer within two days of submitting the payroll submission. In the transitional period, Revenue will refund €410 for every employee on the wage subsidy scheme. In practice, not all employees will be entitled to the full €410. The wage subsidy scheme advanced to employees, must be the correct wage subsidy they are entitled to, in line with above criteria. Any excess subsidy payments received by the employer will be credited against future payments received from Revenue.
Any payments made in excess of the wage subsidy scheme will be subject to income tax and USC as normal through the PAYE system. Such payments must be disclosed separately as taxable income. The tax liability will be mitigated by the employee’s standard rate tax band and tax credits. In many cases the payment of the wage subsidy scheme plus the additional top-up payment will result in a refund in respect of excess PAYE and USC already paid. These refunds can be returned to the employee by the employer, and the employer will subsequently be refunded by Revenue.
Frequently Asked Questions
- Is there a limit on the amount of the top-up payment than can be advanced to employees?
Yes. The top-up payment, when added to the wage subsidy, cannot exceed the employee’s average net salary. If the relevant limit is exceeded the subsidy payment received by Revenue will be tapered accordingly. For every excess €1 paid by the employer in the form of a top-up payment, the employer will lose their entitlement to €1 of the subsidy payment.
- How is the average salary computed?
An employee’s average net salary is computed based on payroll submissions made in January and February 2020. The net salary is computed by deducting from the gross salary received in the period, the PAYE, USC and EE PRSI paid, divided by the number of weeks. This does not include any non -taxable payments (e.g. travel and subsistence payments)
- Is the employee subject to income tax on the wage subsidy payment?
Yes. For the duration of the scheme the payment will not be subject to income tax on a real time basis through the PAYE system. However, the payment is nevertheless taxable income. The employee will be subject to a year end review. If exposure to income tax arises it may be sheltered by excess tax credits available. If there is still an excess liability payable Revenue will collect this tax by reducing the employee’s tax credits for a future year(s).
- Do directors qualify for the wage subsidy scheme?
Yes, provided the employer made a payroll submission on behalf of the director between 1 February and 14 March 2020, he or she qualifies for the wage subsidy scheme.
- How does the wage subsidy scheme operate from a PRSI perspective?
For the duration of the scheme, all qualifying employees will be coded under PRSI Class J9. Employers PRSI will be reduced from 11.05% to .05% and no employee PRSI will apply. Entitlements will not be regarded as broken, and employees will get insurable weeks or credited contributions.
- If an employee has more than one source of employment, are they entitled to claim the wage subsidy scheme more than once?
Yes. Each employer can operate the scheme based on 70% of each qualifying employee’s net wage.
- Can employee pension contributions be deducted from the wage subsidy?
No. However, if the employer is making a top-up payment, the employee’s pension contributions can continue to be deducted from this portion (i.e. the taxable element) of their salary.
- If an employer’s business has been impacted by COVID-19, but the employer has significant cash reserves, is the employer prohibited from applying for the scheme?
No. Such companies are not precluded from applying for the scheme. However, employers should only apply if it is their intentions to make best endeavours to top up the salaries of their employees. Therefore, if a company has strong cash reserves the Government will expect the employer to continue to pay a significant proportion of the employee’s salary.
- How will Revenue verify if an employer qualifies for the scheme?
Revenue’s administration of the scheme will operate largely on the basis of self-assessment and a declaration by the employer concerned. However, Revenue may undertake a review at a later date to verify the employer’s eligibility. In respect of businesses that have ceased trading due to the pandemic, their eligibility for the scheme will be obvious. However, the issue will be more problematic for businesses that continued to trade throughout the crisis. Employers must have on file documentation that will illustrate that their business was significantly impacted due to COVID-19. Such documentation can include, applications made to a bank to negotiate relief measures, notifications sent to a trade unions/ employee representative groups discussing wage cuts, cashflow projections demonstrating that the cash reserves in the company are required to service existing financial commitments, sales forecasts.
*This leaflet sets out our understanding of the COVID-19 Temporary Wage Subsidy Scheme based on the guidance notes currently published on Revenue’s website. Details of the scheme are still being finalised and we expect additional guidance notes to be published in the coming weeks.