On foot of feedback on the TWSS reconciliation process, Chartered Accountants Ireland contacted Revenue with several questions on the process. Among a number of points of clarification, Revenue confirmed that employers with a balance of TWSS due for repayment have until 30 June to make the repayment and can accept the reconciliation before 30 June without triggering an early payment obligation. Revenue also provided guidance for tax agents and employers having difficulty viewing the reconciliation file on ROS. Revenue’s “Employer Guidance for the Temporary Wage Subsidy Scheme (TWSS) reconciliation” was updated on 29 March.

Question: Some employers are worried about repaying TWSS and will delay accepting their reconciliation until such time as they have sufficient cash to make the payment or until 30 June. Can Revenue confirm that it will not ask employers for any payments until after the 30 June? This message may encourage employers to accept the reconciliation sooner rather than later.

Answer: Once employers accept the reconciliation balance, the TWSS liability will be automatically warehoused for employers who are:

• managed by Revenue’s Business or Personal Divisions; or
• already availing of debt warehousing.

Other employers may still apply for debt warehousing if they meet the general criteria.

Employers, not in the debt warehousing scheme, can pay any outstanding reconciliation balance on ROS at any time up to 30 June. This payment can be made after they have accepted their reconciliation.

Where an employer has difficulty in paying the outstanding balance the employer may apply for a Phased Payment Arrangement.

After 30 June 2021, any outstanding balances will be subject to the standard Revenue collection processes.

Question: We understand that Revenue upgraded TWSS to a tax registration (in line with EWSS), but some agents with a ROS sub-certificate do not have automatic permission for the registration which means the tax agent cannot view a client’s TWSS CSV file.

Answer: An updated TWSS Employer Guidance was published on 29 March and included further information on ROS sub-certificates. (See Section 4.2)

Question: If an employer has made any payments towards their liability, these payments are not shown in the TWSS reconciliation file. The payment shows after the employer accepts the reconciliation and then the payments shows on the Statement Of Liability. Some employers are reluctant to accept the statement because it does not include their payments and they do not realise it will show up on the next step.

Answer: Employers will have received a ROS inbox acknowledgement of RevPay payments. The TWSS Employer Guidance explains how the reconciliation and employer payments are combined on the statement of account – to understand their net position employers can deduct any repayments already made from the “Reconciliation Balance”.

Question: Some employers are having difficulty reconciling the CSV back to the payments they received from Revenue. They see that the money received was more than the CSV file indicates but some employers do not understand how income tax/USC refunds interacts with their Monthly Statement.

Answer: The payments made to the employer are visible on their PREM statement of account where the “Wage subsidy payment” and “Wage Subsidy Tax Repayment” are separately itemised. FAQ 5.7 explains the Employer PAYE Statement of Account and shows examples.

Revenue’s Employer Guidance for the Temporary Wage Subsidy Scheme reconciliation was updated on 29 March for the following updates:

• Section 5.3, details on payslips that should not have a subsidy payable value.
• Section 5.4, additional information on interpreting the reconciliation detail CSV file.
• Section 7.1, additional details on subsidy paid information.
• Section 8, additional reconciliation example on an associated payslip.