Clarifications from Revenue on the TWSS reconciliation process

Sep 28, 2020

Revenue has provided the Institute with clarifications for members on the ARNWP in the TWSS reconciliation process and treatment of the “€203 scheme” in the reconciliation process.

Query 1

The ARNWP, which was the basis for determining the subsidy rate, is not subject to correction in the reconciliation process – is that correct?

Revenue response

An employee’s Average Revenue Net Weekly Pay (ARNWP) is based on January and February 2020 payroll submissions made to Revenue for an eligible employee. During the Transitional phase of the TWSS scheme the employer calculated the ARNWP for their employees as outlined in section 4.3 of the FAQ’s. During the Operational Phase, Revenue calculated the ARNWP and provided this to the employer in the employer CSV file. The employer was instructed to use the ARNWP value provided in the Employer CSV file when calculating the subsidy.  For each employer who operated the TWSS Revenue will reconcile all refunds paid to the employer against the amount of subsidy payable to each employee per pay date.  As part of the reconciliation process Revenue will calculate the ARNWP for employees based on information on the Revenue system and calculate the subsequent subsidy payable or due to the employee based on the rules and underpinning legislation of the TWSS scheme.

Query 2

Prior to the TWSS, there was a separate scheme which operated before the legislation was enacted at the end of March, commonly known as the €203 scheme. Paragraph 2 of the Revenue guidance states that the amounts exclude tax, PRSI and USC.  This suggests that this money is not within the scope of TWSS reconciliations, but payroll software appears to be picking up both the TWSS and €203 schemes as reportable which suggests that the €203 is taxable. Can you clarify the position on this for us, please?  What are the exact dates for the scope of the TWSS reconciliation?  

Revenue response

The Employer COVID-19 Refund Scheme was the predecessor to the TWSS scheme and operated from March 12 to March 25, this scheme provided for a flat subsidy amount of €203. The subsidy amount is chargeable to income tax and USC on the employee under Case IV of Schedule D.  

The Reconciliation process is in two stages, stage one requires employers to report the actual subsidy paid to their employees for each pay date, this includes subsidy payments made under the employer COVID-19 Refund Scheme. Employers are required to report this before the end of October 31. The employee will be assessed on the subsidy paid at year end.  Stage two is the calculation process, Revenue will determine the amount of TWSS, if any, owing back to Revenue from employers. This will commence Nov/Dec 2020.  Stage two will not include the Employer COVID-19 Refund Scheme.

Query 3

Will the PSDA issue video tutorials on the subsidy CSV files?

Revenue response

The subsidy CSV file option in the third of a suite of options available to provide subsidy paid data. Employers or their payroll operators should engage with their software provider to determine which of the three options they are supporting. At a recent PSDA meeting Revenue strongly encouraged the providers to inform their clients of the best way to use their software to report the required data – which option are they supporting and how to use it. There were approx. 40 payroll developers on the meeting, and we will repeat this request at future meetings