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This means that if an employer identifies an invalid EWSS claim they must correct payroll records and repay any relevant subsidies along with PRSI credits to Revenue by Friday, 30 September 2022.
This is because Revenue wrote to all employers who claimed subsidies and PRSI credits under the EWSS, and who had not undertaken a Revenue initiated EWSS compliance check.
Generally, to qualify for the EWSS an employer must be able to demonstrate that the business experienced a 30% reduction in turnover or customer orders over relevant comparative periods and that the disruption to normal operations was caused by COVID-19.
A reminder of the comparative periods for an existing business:
Revenue have an EWSS Self-Review Assessment Tool on their website. The tool will assist employers in determining if their business suffered a 30% reduction in turnover or customer orders in the comparative periods.
It should be noted that the tool compares actual turnover/order values. Revenue have clarified that if an employer is deemed ineligible based on actual turnover/order values but the claim for the relevant month was based on projections, then as long as the projections were reasonable, evidenced, and the employer exited the EWSS as soon as it was clear the 30% test was breached, the EWSS may not have to be repaid.
An employer must include all sources of trade income, specifically including sales, donations and State funding. Revenue state that this will likely result in employers in the public, community and voluntary sectors being ineligible as State funding has remained static or, in some sectors, increased.
If the self-review determines that an employer was eligible for all periods, they are not required to submit details to Revenue but rather they should ensure they retain detailed records of the monthly reviews undertaken and all necessary material to support their EWSS claim.
If an employer is eligible for the Debt Warehousing Scheme, any EWSS related payments declared before Friday, 30 September 2022 may be included in this scheme. The benefits of inclusion in the Debt Warehouse Scheme are a 0% rate of interest on tax payments warehoused initially and 3% p.a. applying over the agreed repayment phase.
In tandem with the EWSS self-review, Revenue are conducting an EWSS compliance intervention programme whereby Revenue will initiate a compliance check on those employers who display high risk indicators.
Please contact your Grant Thornton adviser to discuss your EWSS self-review, the Debt Warehousing Scheme and any related matters.
