Oct 2020

Revenue Start Compliance Checks and TWSS Reconciliation

The Temporary Wage Subsidy Scheme – also known as TWSS, was in operation since 26th March, and it ended on 31st August. The subsidy was processed through the payroll as a non-taxable addition, and instead, the subsidy will be taxable and USC-able via an end of year review by Revenue.

Employees will be taxed via a reduction in tax credits and cut off points from 2022. Revenue have confirmed that the liability will be collected over 4 years to avoid hardship. Employees will have the opportunity to pay it in full before then if they wish.

Reconciliation Process Stage One

There are two stages to the TWSS Reconciliation process. For stage one, employers are required to report the actual subsidy that they paid to employees on each pay date.

BrightPay makes it easy to create these TWSS CSV Reconciliation files within the 'Employees' section of the payroll software. The CSV file can then be uploaded in the Employer Services section on ROS, as per Revenue's requirements. This file must be uploaded to ROS by 31st October. If you do not provide this data about payments to your employees, Revenue will recoup the total temporary wage subsidy paid and related interest charges.

Stage Two of the Reconciliation Process

Stage two of the reconciliation process is due to commence later this month, and during this stage, the total subsidy payable amounts will be compared against the subsidy amounts paid to the employer. Revenue will then determine the amount of TWSS, if any, owing back to Revenue from employers.

A Statement of Account will be sent to your ROS inbox. You will either be paid any additional amount due to you by Revenue or be required to repay any amount that you owe to Revenue.

In some cases, an employer may decide, or Revenue may instruct the employer, to repay to Revenue some or all the subsidy refund payment received from Revenue. Employers can repay excess subsidy values to Revenue via a new facility within ROS, this can be done under Payments & Refunds by selecting ’Submit a Payment’ and then TWSS (Employer). Customers should no longer use the Revenue bank account details previously provided for repayments of TWSS.

Only subsidy amounts should be repaid to Revenue through this method - Do not include any repayments in respect of income tax and USC through this RevPay facility. This should be done separately under PAYE EMP to ensure that the payment is correctly reflected on the employers PAYE EMP balance.

TWSS Compliance Check Programme

To ensure that the TWSS was operated correctly, Revenue are conducting a programme of compliance checks on all employers who availed of the scheme at any stage. Letters are being issued to employers and tax agents. Revenue were previously sending these to certain employers/agents via MyEnquiries. Since the start of October, Revenue have started sending them direct to the main ROS inbox, along with all other correspondence, so there’s a greater chance that they could be missed.

The letter will set out the steps that employers need to take to verify their compliance with the regulations of the TWSS.

Employers will need to confirm:

That they have met the eligibility criteria (e.g. details of the negative impact suffered, business closure dates, evidence of meeting 25% reduction in turnover)
That employees received the correct amount of subsidy
That the subsidy was recorded correctly on the payslips (e.g. copies of payslips)

At this point employers are not expected to provide detailed documentation to prove that they have met the employer eligibility criteria but based on the summary provided, Revenue may look for more detailed information in some cases.

What to do if you receive a letter

If you receive such a letter, please note that there is a 5-day time limit to respond to the Revenue’s request. It is essential that employers respond promptly as failure to do so will lead to immediate escalation. Therefore, it is important that employers keep an eye on both the ROS inbox and MyEnquiries or the letter.

This Revenue compliance check is not part of an audit or intervention. Instead, it is a request for information to provide assurance that the scheme was operated as intended by employers.

In addition, the compliance check programme will address any issues identified in respect of the operation of PAYE Modernisation by employers over 2019 and 2020. It will also provide an opportunity for employers to address any other outstanding tax issues that they may have.

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