Revenue released versions 13 through 16 of the FAQ, Guidance on the Operational phase of the COVID 19: Temporary Wage Subsidy Scheme (TWSS) during the month of June 2020.

Updated items included in version 13, issued 29 May:

• Rehiring employees – advice on the processes relating to employees who were removed from payroll and rehired, including steps to take for the inclusion and processing of rehired employees on the TWSS. (Paragraph 2.8)
• Multiple employments – confirmation that earnings from active employments, including retirement benefit/an occupational pension are considered in determining the CSV File figures. (Paragraph 3.12)
• Retirement benefits and ARNWP – confirmation that retirement benefits/pensions payments, subject to income tax through the PAYE system, will be taken into account in calculating the ARNWP. (Paragraph 4.3)
• Using a different value to the ARNWP – further confirmation that the employer risks applying incorrect values to the ARNWP and subsidy calculations, due to the potential for multiple employments, where the figures in the Employers CSV file are not followed. (Paragraph 4.5)
• Entering subsidy information through ROS screen – information for employers not using payroll software or who are entering payroll information manually. (Paragraph 4.18.1)
• Treatment of BIK for eligible employees – information on the treatment of BIKs for employees moving off the TWSS, with the suspended BIK being spread over the remaining payroll periods for 2020. (Paragraph 5.4)
• Reduction or refusal of refunds – further information on subsidy reduction or refusals due to excessive additional gross payments. (Paragraph 5.6)

Updated items included in versions 14 and 15, issued 8 and 12 June, respectively:

• ‘Quick Start’ – an introduction to assist employers in understanding the fundamentals of the scheme and the main steps required to use the scheme.
• How long will TWSS last – updated for government announcement that the TWSS is extended until the end of August 2020. (Paragraph 1.4)
• Rehiring employees – for employees without an eligible Employment ID, using their PPSN, create a new employment with a different Employment ID, with the return to work date as the date their rehire commenced. (Paragraph 2.8)
• How do employers stop operating the scheme – a reminder to employers ceasing the scheme, the PRSI class of all its employees needs to be returned to the correct PRSI class for future payroll submissions. (Paragraph 2.13)
• Employees returning from maternity leave etc. – Revenue are now operating new facilities to allow employers provide the TWSS to employees returning from maternity, adoptive or parental leave or employees who received certain benefits from Department of Employment Affairs and Social Protection (DEASP). Details on how to make a subsidy claim for employees in these circumstances are included in paragraph 3.15.1. The subsidy for these employees can be backdated to 26 March 2020, in certain cases. (Paragraph 3.15)
• Operating the scheme for employees who were on leave and in receipt of DEASP payments – further details on claiming the TWSS for employees who were in receipt of injury benefit or partial capacity benefit. (Paragraph 4.6.1)
• Details to enter when running payroll if claiming TWSS – payroll submissions must include a supported pay frequency. (Paragraph 4.18)
• Treatment of BIK for duration of the scheme – Revenue confirmed that suspended BIK should be spread over the remainder of the payroll periods for 2020. Where this is not possible, the employer needs to report the suspended BIK to Revenue before year end. (Paragraph 5.4)
• Subsidy refunds – where a subsidy refund has not issued, and the reason message is “No TWSS Calculation”; a J9 submission for an employee who does not have an eligible record in the Employer CSV file has been made. (Paragraph 5.6.10)

Updated items included in version 16, issued on 24 June:

• Conditions associated with the TWSS – the eligibility criteria to continue participating or to join the scheme after Q2 remains unchanged. (Paragraph 2.4)
• Rehiring employees – instruct employees to use myAccount to transfer tax credits to active eligible Employment ID, where not already associated. This must be done at least 2 working days before the employer requests the latest Revenue payroll notification (RPN). Employers are encouraged to place rehired employees on a weekly pay frequency to align the pay weeks with the TWSS payments and prevent PUP overlaps. Where this is not practical employers are advised to retain the excess weeks subsidy refund, which will be collected in the reconciliation process. (Paragraph 2.8)
• How to stop operating the scheme – employers will have clarity on whether they met the eligibility criteria at the end of Q2. Employers must immediately cease claiming the TWS where they subsequently realise the eligibility criteria has not been met. No clawback of claims to that date will arise where evidence of assumptions supporting the original self-assessment of eligibility can be shown. (Paragraph 2.13)
• Taxation of the wage subsidy in the hands of the employee – employees who have received the TWS or PUP have been placed on a ‘non-cumulative’ Week 1 basis. Updated RPNs are available in ROS since 21 June. To ensure employees are correctly switched to the Week 1 basis employers need to use the most up to date RPN. (Paragraph 3.11)
• Inclusion of apprentices – Revenue have implemented changes in the TWSS to accommodate apprentices returning to work following education or training programmes with SOLAS. (Paragraph 3.16)
• Details to enter when running payroll – where an employer wants to pay an employee receiving the TWS for multiple pay periods (e.g., two weeks holidays); individual payroll periods need to be reported and paid with different pay dates, otherwise tapering could arise. (Paragraph 4.18)
• Information available to employees – details of the TWS reported to Revenue by the employer can be seen in the employee’s Revenue record on myAccount. Where discrepancies are arising, employees are encouraged to contact their employer to address the matter. Following this, employees are encouraged to contact Revenue where the discrepancies have not been addressed. (Paragraph 7.3)
• Operation of scheme compliance – compliance checks will be conducted for all employers availing of the scheme, through a letter issued to them via myEnquiries. Employers are encouraged to respond promptly to avoid a suspension in future payments. (Paragraph 7.4)

We recommend that members remain familiar with the contents of Revenue’s FAQ, Guidance on the Operational phase of the COVID 19: TWSS, due to the frequency and number of recent updates.