Jobkeeper – CLIENT ALERT

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Do you have more Employees on JobKeeper from 3rd August 2020 – If so, Action required.

If your business is accessing the JobKeeper payment system, the eligibility rules have now changed, key change being the eligibility date has been updated from 1 March 2020 to 1 July 2020.

For any employees that become eligible as a result, the employer must provide notice to the newly eligible employee within 7 days of the commencement of the legislation ie by 21 August 2020, that they might be eligible for Jobkeeper and ask the employee to provide them with a completed JobKeeper Employee Nomination Notice

To assist you in taking the necessary actions by the relevant times, here are some key dates for you;

  1. By 21 August 2020, go through your employee list and identify those staff who are not currently accessing JobKeeper (for example they may have commenced with the business between 1st March – 1st July 2020, so weren’t previously eligible for JobKeeper). If you identify any employees who may now be eligible for Job Keeper, send those employees the ATO employee notification by 21 August 2020. The ATO Employee Nomination Notice can be accessed here. If BPI is looking after your JobKeeper processing, please email Jessica@bpi.com.au
  2. If the employee/s identified above agree to be nominated (and promptly provides you with the completed nomination form), they are eligible for JobKeeper from JobKeeper fortnight 10, which commenced on 3 August 2020.  This means that you will need to ensure they have received the requisite $1,500/fortnight for both the 3 August – 16 August and 17 August – 30 August fortnights. This needs to take place by 31 August 2020 and must also be appropriately recorded in the business’ payroll software
  3. Be careful when completing your August declaration to ensure that all relevant employees are included for the appropriate August fortnights. Note that while three JobKeeper fortnights ended during the month of August, the newly eligible employees will only be eligible for JobKeeper for two of those fortnights.
  4. From 28 September 2020, the employers are required to re-assess their eligibility with reference to the actual GST turnover; rather than the projected GST turnover.

 

Changes to assessment of decline in turnover test

 

To be eligible for the payments between 28 September 2020 to 3 January 2021, businesses and not-for-profits are required to demonstrate that their actual GST turnover has significantly declined only in the September 2020 quarter (previously in both June 2020 and September 2020 quarters) compared to the September 2019 quarter.

To be eligible for the payments between 4 January 2021 to 28 March 2021, businesses and not-for-profits are required to demonstrate their actual GST turnover has significantly declined in December 2020 quarter (previously in June 2020, September 2020 and December 2020 quarters) compared to the December 2019 quarter.

The definition of a significant decline in turnover has not changed and are as follows:

  • 30% fall in turnover for the entity with an aggregated turnover of $1 billion or less;
  • 50% fall in turnover for the entity with an aggregated turnover of more than $1 billion; or
  • 15% fall in turnover for ACNC-registered charities other than universities and schools.

 

The Commissioner of Taxation will have the discretion to set out alternative tests that would establish eligibility in the circumstances that it is not appropriate to compare actual turnover in a quarter in 2020 with actual turnover in a quarter in 2019, in line with the Commissioner’s existing discretion. We expect more information on the alternative tests to be released by the ATO.

 

Reduction in reduced JobKeeper payment rate from 28 September 2020, small changes to criteria for eligibility

 

The payments rates between 28 September 2020 to 3 January 2021 are:

  • $1,200 per fortnight for all eligible employees who, in the four weeks of pay periods before either 1 March 2020 or 1 July 2020, were working 20 hours or more a week on average;
  • $1,200 per fortnight for eligible business participants who were actively engaged in the business for 20 hours or more per week on average;
  • $750 per fortnight for other eligible employees and business participants.

 

The payments rates between 4 January 2021 to 28 March 2021 are:

  • $1,000 per fortnight for all eligible employees who, in the four weeks of pay periods before either 1 March 2020 or 1 July 2020, were working 20 hours or more a week on average;
  • $1,000 per fortnight for eligible business participants who were actively engaged in the business for 20 hours or more per week on average;
  • $650 per fortnight for other eligible employees and business participants

 

 

What else you need to do

 

From 28 September 2020, you should only continue to make JobKeeper payments to your employees, at the reduced rate, if you believe you remain eligible. This will require timely review of the actual GST turnover for September 2020, and if it satisfies the decline in turnover test, prior to making the JobKeeper payment to employees.

 

Similarly, from 4 January 2021, you should only continue to make JobKeeper payments to your employees, at the further reduced rate, if you believe you remain eligible. This will require timely review of the actual GST turnover for December 2020, and if it satisfies the decline in turnover test, prior to making the Jobkeeper payment to employees

Stay safe and best regards.

The Team at BPI

 

 

Our articles are issued as a helpful guide to clients and for their private information. The information provided are general comments and do not constitute or convey advice for personal circumstances. As the situation remains fluid we are committed to providing you with the best support possible

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