Aspire's Health Check: COVID-19 - Don’t let the problem escalate (Part 3)

HM Revenue and Customs (HMRC) recently extended the Coronavirus Job Retention Scheme (CJRS) until the end of October 2020.  We are expecting further guidance to be published by the end of May, detailing the changes to the scheme between August and October, which is expected to require employers to contribute to the scheme and include the possibility for furloughed employees to return to work on a part-time basis.

This means employers will continue to make CJRS claims and it is crucial that these are calculated correctly in preparation for the investigatory work into CJRS claims that is expected to be undertaken by HMRC’s Fraud Investigation Service (see Part 2 of our Health Check publications here for more detail).

Schedule 24 of the Finance Act 2007, “Penalties for Errors”, will likely be HMRC’s position of attack.  HMRC will look at whether an employers’ actions were deliberate or careless and will levy a penalty accordingly.  Our standpoint is that you need to ensure you can demonstrate “reasonable care” has been taken to establish a defendable position should HMRC challenge the eligibility or accuracy of a claim.

Existing Government guidance on the CJRS is still being updated, months on from its initial publication, as well as new guidance also being released. Have you updated and amended your processes and procedures in accordance with this and reviewed your position? Have you got records that document why you made the decisions that you did?

Ensuring that you hold appropriate records in terms of the processes followed to establish eligibility for the CJRS, and the accuracy of any claims made, will be vital in creating a defendable position. It is apparent that Covid-19, whilst potentially on a decline, will become part of our “new normal” and therefore, any interaction with the Government aid provided, should be reviewed, monitored and considered as part of an extension to your business’ due diligence measures.  

Furlough Heath-Check

Don’t let any problems escalate - we are offering a fixed price COVID-19 Health-Check aimed at guiding you through the process and replicating HMRC’s likely approach to a post-Covid 19 investigation.  We will detail recommendations for remedial action which may be taken to reduce potential risks where necessary.

If you would like to arrange a Health-Check please do not hesitate to give us a call on 0121 445 6178 or email enquire@aspirepartnership.co.uk.