COVID-19: Always up to date guidance for small businesses and the self-employed


 

Last updated Thursday 3rd December

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Table of Contents

     

     

    The health of the nation is paramount

    Since the Prime Minister’s initial address on the evening of 23rd March 2020, through the continued measures put in place by the government, the November lockdown and beyond, the priority has been clear: The nation’s health.

    Follow government guidance. Business comes second to your health and the health of the nation.

     

    Still… Confused?

    The chancellor put in place some extraordinary measures to support small businesses and the self-employed amid measures to control the spread of COVID-19, from March right through to the Winter Economy Plan, continuing beyond the Spending Review that concluded this November. But what EXACTLY can you do now if you are a limited company owner/director, self-employed, or on a zero-hours contract!?

    Many are not clear if the available measures include them or not, and there are certainly still many who have been left out.

    If you’re confused by the guidance so far, you’re far from alone.

    We have been constantly monitoring the official advice, releasing podcasts that explain how we think you can benefit and updating this page:

    Podcast 8 looked at the options for SSP for those who were self-isolating due to suffering from those two specific symptoms or following doctor’s advice after contact with someone who had been infected

    Podcast 9 looked at all the measures we understood as of March 25th AM

    Podcast 10 looked at the Coronavirus Job Retention scheme and the Self-Employed income Support scheme, suggesting which might be applicable if you are a limited company owner/director

    Podcast 11 looked at Bounceback Loans, the Kickstart scheme and the inevitible opportunities to pick up other businesses amid the pandemic and subsequent recession

    – Podcast 12, due out soon, will look at the Winter Economy Plan and it’s delayed measures, the lockdown measures and scheme extensions

    This advice is intended for small business owners and the self-employed (through a limited company or as a sole trader) and it will continue to be updated as any new details emerge.

    It doesn’t constitute medical advice! Refer to the proper authorities for that.

     

     

    Beware scams

    Don’t fall for a scam. Refer to the official gov.uk website, and NOT via any link you are sent in an unsolicited message or email, but by TYPING gov.uk into your browser and searching for the information you need using the search box there. If you can’t corroborate an unsolicited text or email you’ve received (e.g. you can’t find the same information for yourself on gov.uk) it’s probably a scam. Just delete the email or message.

     

    ‘Good will payments’

    Beware: “HMRC is aware of COVID-19-Corona Virus SMS scams telling customers they can claim a ‘goodwill payment’.” – see here for latest official details: https://www.gov.uk/government/publications/phishing-and-bogus-emails-hm-revenue-and-customs-examples/phishing-emails-and-bogus-contact-hm-revenue-and-customs-examples

     

    ‘£250 fine’

    Another one: “HMRC is aware of a SMS scam which states you will be fined £250 for leaving the house more than once. The message asks recipients to call an 0800 telephone number to appeal.” – you should neither reply, nor call the number. Even though the link in the SMS is to gov.uk/coronavirus, a legitimate resource (which is particularly troubling as it will lend confidence to the legitimacy of the SMS to those who follow the link) the SMS itself IS a scam. It is also listed on https://www.gov.uk/government/publications/phishing-and-bogus-emails-hm-revenue-and-customs-examples/phishing-emails-and-bogus-contact-hm-revenue-and-customs-examples

     

    ‘Tax refund’ email

    “HMRC is aware of a phishing campaign telling customers they can claim a tax refund to help protect themselves from the coronavirus outbreak.” – again, ignore and delete. This is also listed on https://www.gov.uk/government/publications/phishing-and-bogus-emails-hm-revenue-and-customs-examples/phishing-emails-and-bogus-contact-hm-revenue-and-customs-examples

     

     

     

    Regarding the Sick, Self-Isolating or ‘Shielding’

     

    If you are sick or self-isolating due to doctor’s advice or because you or someone else in your household or ‘support bubble’ has recently displayed any of the three identified symptoms or tested positive for coronavirus, because you are ‘shielding’ in an area with local restrictions in place, or because you have been asked to self-isolate as part of ‘track and trace’ or in advance of surgery:

    If you are on PAYE and have been regularly drawing a salary of more than the Lower Earnings Limit (£120 per week or £520 per month), you can claim SSP from day 1 through your payroll system/provider. No doctors note is required, simply keep a record. That’s £95.85 per week drawn from your company, and the government will reimburse up to 2 weeks of this (though, if self-isolating in advance of surgery, only the days of self-isolation in advance of surgery may be reclaimed this way, and not the day of surgery or subsequent recovery period) – the mechanism for this is now available here, and it is based on the SSP having been noted on a proper payroll system linked electronically to HMRC via the so-called Real Time Information system. If you outsource your payroll, they should be able to help. If you do it yourself, refer to your payroll software provider, and make the proper claim yourself here.

    For guidance on what you need to record, see here: https://www.gov.uk/guidance/claim-back-statutory-sick-pay-paid-to-employees-due-to-coronavirus-covid-19

    You do not have to use SSP if, for example, you have furloughed yourself and your furloughed rate of pay is greater than SSP.

    If you do not pay yourself via PAYE, like many limited company owners who pay themselves only dividends and the self-employed who calculate submit accounts and pay tax annually, Employment and Support Allowance is your first option for sick pay and is subject to pretty much the same restrictions above. Find out more here: https://www.gov.uk/employment-support-allowance

    Note: Staying at home more generally due any ‘local lockdown’ will not count for the purpose of claiming sick pay, either through ESA or SSP. Nor does quarantining upon your return to the UK, unless any of the other conditions in this section title also apply.

     

    If you are an employer, and some of your employees are off sick or self-isolating due to doctor’s advice or because they or someone else in their household or ‘support bubble’ has recently displayed any of the three identified symptoms or tested positive for coronavirus, because they are ‘shielding’ in an area with local restrictions in place, or because they have been asked to self-isolate as part of ‘track and trace’ or in advance of surgery:

    For PAYE employees, you must pay at least SSP, in which case you should do so from day 1 with no fit note required. The government will later reimburse you if you had fewer than 250 employees on 28th February 2020, for up to two weeks per employee (see above, same advice, including the caveat on self-isolation in advance of surgery).

    The mechanism to reclaim SSP costs is now available here, and it is based on the SSP having been noted on a proper payroll system linked electronically to HMRC via the so-called Real Time Information system. If you outsource your payroll, they should be able to help. If you do it yourself, refer to your payroll software provider, and make the proper claim yourself here.

    For guidance on what you need to record, see here: https://www.gov.uk/guidance/claim-back-statutory-sick-pay-paid-to-employees-due-to-coronavirus-covid-19

    You do not have to use SSP if, for example, you have furloughed staff and their furloughed rate of pay is greater than SSP – since both of these may be reclaimed, it would most likely be better for them (and no worse for you) to keep them on their furloughed rate of pay. You must pay them at least SSP if they are sick, though, if for example their furloughed rate of pay is less than this.

    Note that though employees ‘shielding’ amid a ‘local lockdown’ according to public health guidance are entitled to SSP (if they cannot work while shielding), for the full period that shielding may last, you can only reclaim up to 2 weeks of this SSP – you can request a ‘shielding note’ or letter from their doctor for this. It may make more sense, as above, to furlough these workers, as that can be reclaimed, if they are eligible to be furloughed.

    For self-employed and limited company contractors – I am sure they know they are not entitled to sick pay from you, but you can direct them to ESA, as above. (You could also direct them here, as this page is intended for such folks!)

    That’s it for sick pay.

    Since neither of these are particularly satisfactory on their own, all affected should also consider Universal Credit, further below.

     

     

    Regarding paying your employees

     

    Support for paying your PAYE employees:

    If they are working, pay them normally if you can. If there is no work for them to do, you can furlough them.

    The ‘furlough’ status, part of the Coronavirus Job Retention Scheme, is for workers on the payroll but sent home without work to do, and is preferable to laying them off. HMRC previously tapered off the amount they would pay from the original 80% of their ‘regular earnings’ (“such as wages, compulsory commission and fees are past overtime” but not “discretionary commission (including tips) payments or bonuses, non-cash payments or benefits in kind” – up to £2,500 per month) down to 60% of those same earnings (up to £1,875) for October. It since raised the amount back to 80% as the November lockdown arrived, however, continuing through to 31st March 2021 (although the need for this will be reviewed in January)

    The Job Support Scheme (which was first announced as part of the Winter Economy Plan) is intended to replace the Coronavirus Job Retention Scheme, but it has been delayed indefinitely due to the November lockdown and subsequent extension of the former scheme. When it does finally come, “employers will continue to pay the wages of staff for the hours they work – but for the hours not worked, the government and the employer will each pay one third of their equivalent salary. […] employees must be working at least 33% of their usual hours. The level of grant will be calculated based on employee’s usual salary, capped at £697.92 per month.” though on 22nd October, less than a month after being revealed, the scheme was changed such that: “Now, we will ask them to work only 20% of their hours. Second, the employer contribution for the hours not worked will not be 33%, as originally planned, or even 20% as it is in the October furlough scheme – it will reduce to 5%” – Time will tell what final form this scheme will take, and when it will be implemented.

    Employees do not need to have been previously furloughed in order to be eligible for the extended Coronavirus Job Retention Scheme, and instead need only to have been on the payroll on or before 30th October. Workers made redundant but previously on the payroll on or before 23rd September 2020 can be brought back under this scheme.

    The previously announced £1,000 Job Retention Bonus that was due to become available in February 2021 has, in light of the lockdown and extension to the Coronavirus Job Retention Scheme, been postponed indefinitely.

    The Coronavirus Job Retention Scheme online portal remains open, but the page has not been updated for the November period. You can find it at: https://www.gov.uk/guidance/claim-for-wages-through-the-coronavirus-job-retention-scheme

    Due to the close of the prior incarnation of the Coronavirus Job Retention Scheme and the indefinitely delayed Job Support Scheme and Job Retention Bonus, the previous guidance regarding these schemes on this page has now been removed – the appropriate content for the current situation remains. We await further guidance on the end of the Coronavirus Job Retention Scheme, the Job Support Scheme and the Job Retention Bonus as and when these items are announced.

     

    Support for paying your self-employed workers:

    Since 26th March, four grant packages for the self-employed (the Self-Employment Income Support Scheme or SEISS) have been outlined. The first was available until 13th July, worth 80% of average monthly profits over the previous 3 years, up to £2,500 per month, for 3 months, provided as a single instalment. The second grant was available from 17th August until 19th October, for 70% of this same average, to cover an additional three months.

    Though it has been noted by multiple commentators that this sum total of 6 months of support intended to ‘mirror’ the 8 months of support handed to employees who were furloughed between March and October inclusive represents a somewhat unfair scenario for the self-employed (not to mention the ceiling of £50,000 average earnings above which no help whatsoever is made available – a ceiling which does not exist for those furloughed), the chancellor has steadfastly refused to offer any additional support, even under sustained pressure from the Treasury Select Committee to address these easily resolved issues.

    When the November lockdown was announced, replacing the previously announced Winter Economy Plan, two further extensions of the Self Employment Income Support Scheme were included, with the third specified again at 80%, in a single payment capped at £7,500. Details of the fourth scheme have yet to emerge.

    If eligible (see below), your self-employed workers would have been and will be able to claim each of these grants while continuing to do business, even if you yourself have limited or no work for them.

    The scheme has been open to anyone with trading profits up to £50k for whom they make the majority of their income from self-employment, and who are already in self-employment, with a 2018-19 tax return filed. (The Chancellor has since explicitly stated that neither eligibility nor the calculation will extend to 2019-20 self assessments.) They can check if they’re eligible to claim for Self Employed Income Support Scheme at https://www.tax.service.gov.uk/self-employment-support – however, the benefit of this tool may be limited, given that HMRC will have worked out who is eligible and written to them, anyway.

    Note that “If you receive the grant you can continue to work, start a new trade or take on other employment including voluntary work, or duties as an armed forces reservist.” Also, “If you have other employment as a director or employee paid through PAYE your employer may be able to get support using the Coronavirus Job Retention Scheme” highlighting that use of one scheme does not necessarily preclude the use of the other for those with both Limited company directorships and/or PAYE employment and Self Employment.

    The grants were and are applied for via a simple online form, with money going straight into successful applicants’ bank accounts. HMRC wrote to those they believed to be eligible for these grants.

    The online portal for the first grant opened on 13th May and closed on 13th July. The online portal for the second grant became available on 17th August, and closed on 19th October. The third grant opened for applications on 30th November. Though an individual does not need to have claimed a previous grant to be eligible for the subsequent grants, the eligibility for this third grant is somewhat stricter. Specifically, rather than simply having been “adversely affected”, they must now be confident that they will have “significantly reduced profits” for their basis period (e.g. this tax year, for most) – increased costs alone are insufficient. Note that they must also keep evidence of the justification of their eligibility.

    New guidance was published to help with understanding the new criteria, entitled “How your trading conditions affect your eligibility for the Self-Employment Income Support Scheme”, though for those comfortable with legalese, the Treasury direction made by the Chancellor brings the most precise wording. Our interpretation is that they must be able to confidently predict that profits from their self-employed trade (ignoring any other kinds of income they receive) will be significantly (however they feel they can justifiably interpret the meaning of ‘significantly’) down for this tax year, due to reduced activity, capacity or demand (i.e. reduced sales) between 1st November and 29th January attributable to coronavirus, at the time they claim, and they must keep evidence to that effect.

    HMRC guidance on the scheme can be found here: https://www.gov.uk/guidance/claim-a-grant-through-the-coronavirus-covid-19-self-employment-income-support-scheme

    Also, a ‘How to make a claim’ video was added on 14th May, here

    For those who need further cash flow support, consider the other schemes here such as the Bounce Back Loan, Coronavirus Business Continuity Loan, deferred income tax payment, and the welfare system such as Universal Credit.

     

    Support for paying limited company contractors:

    HMRC allows the ‘furlough’ status to apply to limited company owner/directors who pay themselves a salary via PAYE – see the ‘Company Director’s heading in the ‘employers’ document regarding the Coronavirus Job Retention Scheme: https://www.gov.uk/guidance/claim-for-wage-costs-through-the-coronavirus-job-retention-scheme#employees-you-can-claim-for

    Unlike the self-employed, they were and are unable to continue to work as normal for furloughed hours.

    If your limited company contractors are explicitly excluded given the rules for this scheme, e.g. if they pay themselves dividends only, Universal Credit and the other help noted toward the bottom of this page may be all that is available.

     

    Regarding paying yourself, the business owner

     

    As a sole-trader:

    Since 26th March, four grant packages for the self-employed (the Self-Employment Income Support Scheme or SEISS) have been outlined. The first was available until 13th July, worth 80% of average monthly profits over the previous 3 years, up to £2,500 per month, for 3 months, provided as a single instalment. The second grant was available from 17th August until 19th October, for 70% of this same average, to cover an additional three months.

    Though it has been noted by multiple commentators that this sum total of 6 months of support intended to ‘mirror’ the 8 months of support handed to employees who were furloughed between March and October inclusive represents a somewhat unfair scenario for the self-employed (not to mention the ceiling of £50,000 average earnings above which no help whatsoever is made available – a ceiling which does not exist for those furloughed), the chancellor has steadfastly refused to offer any additional support, even under sustained pressure from the Treasury Select Committee to address these easily resolved issues.

    When the November lockdown was announced, replacing the previously announced Winter Economy Plan, two further extensions of the Self Employment Income Support Scheme were included, with the third specified again at 80%, in a single payment capped at £7,500. Details of the fourth scheme have yet to emerge.

    If eligible (see below), you would have been and will be able to claim the grants while continuing to do business.

    The scheme has been open to anyone with trading profits up to £50k for whom they make the majority of their income from self-employment, and who are already in self-employment, with a 2018-19 tax return filed. (The Chancellor has since explicitly stated that neither eligibility nor the calculation will extend to 2019-20 self assessments.) You can check if you’re eligible to claim for Self Employed Income Support Scheme at https://www.tax.service.gov.uk/self-employment-support – however, the benefit of this tool may be limited, given that HMRC will have worked out if you are eligible and written to you, anyway.

    Note that “If you receive the grant you can continue to work, start a new trade or take on other employment including voluntary work, or duties as an armed forces reservist.” Also, “If you have other employment as a director or employee paid through PAYE your employer may be able to get support using the Coronavirus Job Retention Scheme” highlighting that use of one scheme does not necessarily preclude the use of the other for those with both Limited company directorships and/or PAYE employment and Self Employment.

    The grants were and are applied for via a simple online form, with money going straight into successful applicants’ bank accounts. HMRC wrote to those they believed to be eligible for these grants.

    The online portal for the first grant opened on 13th May and closed on 13th July. The online portal for the second grant became available on 17th August, and closed on 19th October. The third grant opened for applications on 30th November. Though an individual does not need to have claimed a previous grant to be eligible for the subsequent grants, the eligibility for this third grant is somewhat stricter. Specifically, rather than simply having been “adversely affected”, you must now be confident that you will have “significantly reduced profits” for your basis period (e.g. this tax year, for most) – increased costs alone are insufficient. Note that you must also keep evidence of the justification of your eligibility.

    New guidance was published to help with understanding the new criteria, entitled “How your trading conditions affect your eligibility for the Self-Employment Income Support Scheme”, though for those comfortable with legalese, the Treasury direction made by the Chancellor brings the most precise wording. Our interpretation is that you must be able to confidently predict that profits from your self-employed trade (ignoring any other kinds of income you receive) will be significantly (however you feel you can justifiably interpret the meaning of ‘significantly’) down for this tax year, due to reduced activity, capacity or demand (i.e. reduced sales) between 1st November and 29th January attributable to coronavirus, at the time you claim, and you must keep evidence to that effect.

    HMRC guidance on the scheme can be found here: https://www.gov.uk/guidance/claim-a-grant-through-the-coronavirus-covid-19-self-employment-income-support-scheme

    Details on how HMRC will calculate what you can claim can be found here: https://www.gov.uk/guidance/how-hmrc-works-out-total-income-and-trading-profits-for-the-self-employment-income-support-scheme

    Also, a ‘How to make a claim’ video was added on 14th May, here

    For those who need further cash flow support, consider the other schemes here such as the Bounce Back Loan, Coronavirus Business Continuity Loan, deferred income tax payment, and the welfare system such as Universal Credit.

    A point to keep in mind for when this economic emergency starts to wane: the Chancellor, consistent with the concept of never letting a crisis go to waste (so loved by politicians), used the opportunity to promote the concept that this makes it “harder to justify inconsistent contributions” of the self-employed saying “we must all pay in equally in future”. It would appear that the government intends to conflate its responsibility toward the safety and security of all its citizens, and how it gathers contributions from society as a whole, with the differing in-work risks, protections and National Insurance benefits available to the self-employed vs employed workers. It also seems intent on ignoring that it has provided less support for those who are self-employed than it has for those employed, somewhat undermining the premise of the argument.

     

    As a limited company owner/director:

    The Self-Employed Income Support scheme is not applicable to a limited company owner/director, so you can only claim through the Coronavirus Job Retention scheme, if eligible.

    You do not have to have previously furloughed yourself in order to qualify for the extended Coronavirus Job Retention Scheme.

    Guidance regarding the previous incarnation of the Coronavirus Job Retention Scheme and the previously planned but indefinitely delayed Job Support Scheme has been removed from this page – the relevant details for the current situation remain.

    If, in addition to your directorship, you are also self-employed, you should note that regarding the Self Employment Income Support Scheme: “If you receive the grant you can continue to work, start a new trade or take on other employment including voluntary work, or duties as an armed forces reservist.” and “If you have other employment as a director or employee paid through PAYE your employer may be able to get support using the Coronavirus Job Retention Scheme” – This highlights that use of one scheme does not necessarily preclude the use of the other for those with both Limited company directorships and/or PAYE employment and Self Employment – but note that HMRC has since explicitly stated that this scheme should not be used if you have incorporated that trade since 5 April 2018

    We await further guidance on the end of the Coronavirus Job Retention Scheme and the indefinitely postponed Job Support Scheme as and when these items are announced. For now, you may refer to the provided factsheet.

     

    As a previously self-employed individual who has recently incorporated

    You may have been written to by HMRC regarding the Self-Employment Income Support Scheme (SEISS), if they believed you to be eligible. However, the following statement was added to the SEISS guidance document on 13th May: “You should not claim the grant if you’re a limited company”, this was not well written (a limited company is a separate legal entity to an individual: Use of the word ‘you’re’ indicates the limited company itself may not claim, but a self-employed individual who happens to also be a person of significant control (e.g. sole director) of a limited company would not seem to be specifically excluded from claiming by this statement, if they are otherwise eligible.) but on 14th July it was quietly amended to say “You cannot claim the grant if you trade through a limited company”. This has similar wording issues, though, as it seems principally incorrect to exclude those who are both self-employed and operate a limited company, but with different trades, or to retrospectively exclude those who have very recently incorporated their previously self-employed trade.

    Though this wording change was made after the close of the first grant, making it seem hard to enforce in that instance, the swift changes in legislation would appear to have granted HMRC sweeping powers administering these schemes, and the guidance ‘Tell HMRC and pay the Self-Employment Income Support Scheme grant back‘ retrospectively adds clarity to the eligibility criteria with the statement: “You must tell HMRC if when you made the claim you: […] were not eligible for the grant, for example: […] you have incorporated your business since 5 April 2018” – the same document outlines how to report this to HMRC and the penalties that may be enforced e.g. if you do not willingly report it to HMRC. The deadline to avoid all such penalties was 20th October. Such overpayments are recovered as a tax payment equal to the overpaid grant amount, which would seem to make them eligible for the currently extended repayment terms available through the Time to Pay service (see elsewhere in this document.)

    Your only options are those outlined for limited company directors, above.

     

    Not covered sufficiently by either schemes?

    For now, if it appears you will need to turn to Universal Credit and the other help noted toward the bottom of this page.

     

     

    Grants and Business Rate Relief

     

    Can you get a grant?

    If you occupy a property, are a retail, hospitality or leisure business and you pay business rates, or if you’re a small business in any sector that occupies a property and would pay business rates if it weren’t for Small Business Rate Relief or Rural Rate Relief, your local authority (e.g. your local council) will have written to you. See the main document for more info. Note that though the local authority will have written to you, some also operated an applications procedure.

    Prior to the November lockdown, the Chancellor had announced that grants (previously £1,500 every three weeks) were increased, with businesses eligible after only two weeks of closure rather than three: “Small businesses with a rateable value of or below £15,000 can now claim £1,300 per month; medium sized businesses with a rateable value between £15,000 and £51,000 can claim £2,000 per month; and larger businesses can claim £3,000.” No mention has yet been made about any change to the amounts previously available via discretionary local authority funds for businesses affected by closures but not on rates lists, which was up to £1,500, according to the discretion of the local authority.

    For the November national lockdown, is was announced that “Businesses required to close in England due to local or national restrictions will be eligible for the following: For properties with a rateable value of £15k or under, grants to be £1,334 per month, or £667 per two weeks; For properties with a rateable value of between £15k-£51k grants to be £2,000 per month, or £1,000 per two weeks; For properties with a rateable value of £51k or over grants to be £3,000 per month, or £1,500 per two weeks.”

    Other grants may still be available through your local Growth Hub as per this press release.

    (For details regarding Self-Employment Income Support Scheme grants, see above sections)

     

    Can you get a Business Rates Holiday?

    If you are a retail, hospitality, leisure or nursery business. No action required, the council tax bill should have applied this (a bill may need to be reissued but that should now have been taken care of). Again, see the main document for more info.

     

    Otherwise?

    A relatively unpromoted press release was made on 2nd May by several government departments, speaking of a “Top-up to local business grant funds scheme” designed “to accommodate certain small businesses previously outside the scope of the business grant funds scheme.” The release states: “We are asking local authorities to prioritise businesses in shared spaces, regular market traders, small charity properties that would meet the criteria for Small Business Rates Relief, and bed and breakfasts that pay council tax rather than business rates. But local authorities may choose to make payments to other businesses based on local economic need. The allocation of funding will be at the discretion of local authorities. Businesses must be small, under 50 employees, and they must also be able to demonstrate that they have seen a significant drop of income due to Coronavirus restriction measures. There will be three levels of grant payments. The maximum will be £25,000. There will also be grants of £10,000. local authorities will have discretion to make payments of any amount under £10,000. It will be for councils to adapt this approach to local circumstances.”

    Since then, on 29th May a new guidance document was added to cover the so-called Local Authority Discretionary Grants Fund, whereby “Small and micro businesses with fixed property costs that are not eligible for the Small Business Grant Fund or the Retail, Hospitality and Leisure Grant Fund may be eligible for the Discretionary Grants Scheme.” – though this document currently redirects you to your local council to apply. However, by this time, most councils will likely have run out of these limited, discretionary funds.

     

     

    Can you get a ‘loan’ by putting off your existing liabilities?

     

    Registered for VAT?

    A loan of a sort, if you caught the opportunity: a holiday from your VAT bill was available between 20 March 2020 until 30 June 2020.

    Explicit guidance was added to state that: if you are VAT registered and want to defer your next VAT payment for the bill that would have been due between 20th March and 30th June 2020, you should cancel your direct debit.

    “Customers who normally pay by direct debit should cancel their direct debit with their bank if they are unable to pay. Please do so in sufficient time so that HMRC do not attempt to automatically collect on receipt of your VAT return.”

    Though this specific statement has since been removed, the advice remains in the official HMRC guidance document. Previously, it was stated that this will incur no penalties or interest for late payment provided you “pay the VAT due on or before 31 March 2021” but the Winter Economy Plan introduced an extension to this, stating you “now have the option to pay in smaller payments over a longer period […] Instead of paying the full amount by the end of March 2021, you can make smaller payments up to the end of March 2022, interest free. You will need to opt-in to the scheme, and for those who do, this means that your VAT liabilities due between 20 March and 30 June 2020 do not need to be paid in full until the end of March 2022. Those that can pay their deferred VAT can still do so by 31 March 2021. […] More information on the scheme will be available on GOV.UK in the coming months.” – details are not yet available, but the VAT deferral guidance page does now provide an outline of this scheme.

    You could have deferred quarterly and monthly VAT returns’ payments for the periods ending in February, March and April; payments on account due between 20 March 2020 and 30 June 2020; and annual accounting advance payments due between 20 March and 30 June 2020.

    This deferral did not apply payments for VAT MOSS or import VAT.

    The scheme is now closed and direct debits should be set up again for future VAT payments.

    An official HMRC document on this was produced, available here: https://www.gov.uk/guidance/deferral-of-vat-payments-due-to-coronavirus-covid-19

     

    Owe the Taxman?

    “All businesses and self-employed people in financial distress, and with outstanding tax liabilities, may be eligible to receive support with their tax affairs through HMRC’s Time To Pay service.

    These arrangements are agreed on a case-by-case basis and are tailored to individual circumstances and liabilities.”

    Again, a loan of a sort: the possibility of deferring payment on any self-assessment payments you are already late with.

    Though you would previously have been directed to call the ‘Time to Pay’ helpline (0800 024 1222), the system will now serve you online. In particular, subsequent to the Winter Economy Plan, HMRC extended the tax liability limit for the ‘Time To Pay’ service from £10k to £30k for those who complete Self Assessments so that “customers could pay their deferred payment on account bill from July 2020, any outstanding tax owed for 2019 to 2020 and their first payment on account bill for this current tax year in monthly instalments, up to 12 months, via this self-serve tool.” Noting in particular that “HMRC estimates around 95% of Self Assessment customers who are due to make payments on 31 January 2021 could qualify to implement a Time to Pay arrangement using the self-serve Time to Pay facility online, without needing to speak to an HMRC adviser.” – but also be advised that “the payment plan needs to be set up no later than 60 days after the due date of a debt” – for more details see here

    Note that, on 14th August, HMRC published a policy paper entitled ‘How HMRC deals with and supports customers who have a tax debt’, which may be of use in particular if COVID-19 has resulted in getting behind with tax payments (other than 31st July 2020’s payment on account, which has an automatically adjusted due date of 31st January 2021 – see below)

     

    Paying Self-Assessment Contributions in Advance?

    And another loan of a sort: “Income Tax Self-Assessment, payments due on the 31 July 2020 will be deferred until the 31 January 2021.” (and since qualifying for the Time to Pay scheme beyond January) – if this applies to you.

    On 15th May, a guidance document was introduced for those who complete Self Assessments and would have a payment on account due in July, to help them “Choose how and when you can delay making your second payment on account for the 2019 to 2020 tax year” – in particular, stating that “You do not need to tell HMRC that you’re deferring your payment on account.” and “HMRC will not charge interest or penalties on any amount of the deferred payment on account, provided it’s paid on or before 31 January 2021”

    HMRC even accidentally sent letters explicitly applying this as a new due date: “The June 2020 Self Assessment statements showed 31 January 2021 as the due date for paying the July 2020 Payment on Account. This is because HMRC updated their IT systems to prevent customers incurring late payment interest on any July 2020 Payment on Account paid between 1st August 2020 and 31 January 2021. The deferment has not been applied for all customers by HMRC and it remains optional.”

    Since then, subsequent to the Winter Economy Plan, HMRC extended the tax liability limit for the ‘Time To Pay’ service from £10k to £30k for those who complete Self Assessments so that “customers could pay their deferred payment on account bill from July 2020, any outstanding tax owed for 2019 to 2020 and their first payment on account bill for this current tax year in monthly instalments, up to 12 months, via this self-serve tool.” Noting in particular that “HMRC estimates around 95% of Self Assessment customers who are due to make payments on 31 January 2021 could qualify to implement a Time to Pay arrangement using the self-serve Time to Pay facility online, without needing to speak to an HMRC adviser.” – but also be advised that “the payment plan needs to be set up no later than 60 days after the due date of a debt” – for more details see here

    If you are due to repay a Self Employment Income Support Scheme grant that you were overpaid or ineligible for, since it is recovered via a tax payment equal to the overpaid amount, this presumably also would fall under this extended scheme.

     

    Cannot pay your commercial rent?

    The government has now said that “Commercial tenants who cannot pay their rent because of COVID-19 will be protected from eviction.” for missed payments until 30th June, since extended to 30th September, and then again to the end of 2020. It’s another ‘loan in effect’ as it is not a holiday and you will still be liable for the rent.

     

    Have one or more existing loans?

    Consider contacting your lender(s) and arrange a payment holiday if at all possible, thereby effectively getting a ‘loan’ at the amount of your existing repayments in the short term, with no new liabilities to add to your balance sheet.

    On this very topic, on 2nd April, the Financial Conduct Authority proposed temporary financial relief for customers impacted by coronavirus, later confirming those measures on 9th April. These measures include firms being expected to:

    “Offer a temporary payment freeze on loans and credit cards for up to three months, for consumers negatively impacted by coronavirus”

    “Allow customers who are negatively impacted by coronavirus and who already have an arranged overdraft on their main personal current account, up to £500 charged at zero interest for three months”

    “Make sure that all overdraft customers are no worse off on price when compared to the prices they were charged before the recent overdraft pricing changes came into force” (most banks had recently raised their overdraft interest rates to 39.9% in response to these changes)

    “Ensure consumers using any of these temporary payment freeze measures will not have their credit file affected”

    These measures have been specifically noted to include: “guarantor loans, logbook loans, home collected credit, a loan issued by Community Development Finance Institution and some loans issued by credit unions, but only where these are regulated. The guidance also applies to firms which have acquired such loans. These measures won’t replace normal forbearance rules where these would be more suitable for a consumer in serious and immediate financial difficulty”

    The press release on these confirmed measures can be found here and these measures are in effect as of 14th April, with extensions to some o fthese measures since confirmed on 1st July here

    Also, as of 27th April, FCA rules are in effect to ensure consumers can access “a 3 month payment freeze for motor finance, buy-now pay-later (BNPL), rent-to-own (RTO) and pawnbroking agreements. For high-cost short term credit (including payday loans) payments will be frozen for one month with no additional interest to be charged.” with a further 3 months freeze available if needed, confirmed on 15th July – see here for details.

    The next stage of these protections were proposed on 16th September (which would, for example, require firms to “give customers time and opportunity to repay and do not pressurise them into repaying their debt within an unreasonably short period of time”) and these were confirmed on 30th September.

     

     

    Need a real loan?

     

    ‘Bounce Back’ Loans:

    On 27th April, the government announced a new ‘Bounce Back Loan’ scheme: “whereby businesses will be able to borrow between £2,000 and £50,000 and access the cash within days […] interest free for the first 12 months, and businesses can apply online through a short and simple form”

    This is a “new fast-track finance scheme providing loans with a 100% government-backed guarantee for lenders […]  designed to ensure that small firms who need vital cash injections to keep operating can get finance in a matter of days […] No repayments will be due during the first 12 months.”

    Also, “the government will work with lenders […] and agree a low standardised level of interest for the remaining period of the loanwhich has since been confirmed at the incredibly low rate of 2.5%

    The scheme opened for applications on Monday 4 May via https://www.british-business-bank.co.uk/ourpartners/coronavirus-business-interruption-loan-schemes/bounce-back-loans/ – but  no single “short and simple form” is actually available, as all potential applicants are directed to choose a lender and find out how to apply through them, individually. However, a Treasury press release claims that (presumably for each lender) “small business owners can apply to accredited lenders by filling out a simple online form, with only seven questions.”

    Notably, in contrast with the older Coronavirus Business Interruption Loans (below) that many small businesses have struggled to apply for: “There will be no forward-looking tests of business viability; no complex eligibility criteria; just a simple, quick, standard form for businesses to fill in.” and “For most firms, loans should arrive within 24 hours of approval.”

    Such a rosy picture would not appear to have been borne out by events, however, with most institutions only offering these loans to existing customers, and the whole process taking weeks to complete.

    The best resource for information on loan availability seems to be moneysavingxepert.com, who have an excellent article and list of Bounce Back Loan providers. Though, on 6th October, the BBC reported that “Of the 28 accredited lenders on the bounce back loan site, only two appear to offer loans to non-customers: peer-to-peer site Funding Circle, and Capital on Tap.” No high street banks are currently offering the ability to apply to non-customers as HSBC, the last such bank, “closed its doors to new customers last week.” This has locked out many small businesses from applying for such help, which is of particular concern since “The deadline for bounce back loan applications is 30 November, which means time is running out for firms who have yet to secure a loan” – though this deadline has since been extended amid the November lockdown to 31st January 2021

    Small and medium sized businesses may “borrow between £2,000 and up to 25% of their turnover. The maximum loan available is £50,000.” also “there won’t be any fees or interest to pay for the first 12 months. After 12 months the interest rate will be 2.5% a year.” suggesting that interest will not accrue immediately. Also, “The length of the loan is 6 years, but you can repay early without paying a fee. No repayments will be due during the first 12 months.” Additionally, as part of the Winter Economy Plan, “a new Pay as You Grow flexible repayment system” was announced “extending the length of the loan from six years to ten, which will cut monthly repayments by nearly half. Interest-only periods of up to six months and payment holidays will also be available to businesses.”

    So, regardless of the difficulty in applying, this is cheap lending available in a widespread fashion and, if you have a use for it, it may be worth seriously considering while it is available – especially considering your competition likely also has access to such a facility.

    However, I am not reassured by the statement: “The lender will decide whether to offer you a loan or another type of finance” as it makes me wonder whether lenders may choose to direct you to products that are more profitable to themselves, rather than this scheme, after you apply. Though it is reassuring to note that “If one lender turns you down, you can apply to other lenders in the scheme”

    It’s shaping up to be a popular avenue, as “More than 69,000 Bounce Back Loans worth over £2 billion have been approved during the first 24 hours of the scheme” (according to this press release from HM Treasury), with almost £8.4 billion having been lent via over 268,173 loans by 11th May (see here)

    Note that you cannot apply if you’re already claiming under the Coronavirus Business Interruption Loan Scheme (CBILS). However, if you’ve already received a loan of up to £50,000 under CBILS and would like to transfer it into the Bounce Back Loan scheme, you can arrange this with your lender until 4 November 2020.

    Also note that the eligibility criteria that a business “was not an ‘undertaking in difficulty’ on 31 December 2019” has now been removed from the bounce back loan scheme, meaning that such businesses may apply, and clarity has since been added that the scheme is only open to businesses “established before 1 March 2020”

    Most of the cautionary statements below will still apply here.

     

    Coronavirus Business Interruption Loan:

    Coronavirus Business Interruption Loans are available up to £5m for 6 years, for businesses with a revenue of up to £45m, with no interest payments due for the first 12 months. The fact that the government is providing the lenders with a guarantee worth 80% of the value is neither here nor there, you’ll have to pay this loan back and with interest.

    (Note: a similar scheme, introduced on 3rd April, for larger businesses was announced – The Coronavirus Large Business Interruption Loan Scheme – for businesses with a turnover between £45m and £500m, though we shall not cover it here due our audience being predominantly small-business. See the press release for more info.)

    Until the scheme rules changed on 3rd April, personal guarantees were still often a requirement due to the government’s insistence (presumably to protect the taxpayer) that the lender’s normal lending criteria apply. Not only that, but the rules stated that businesses must have been refused for a commercial lending product first – both details that were not made clear to the small businesses hoping to take advantage of the scheme, making banks an immediate scapegoat as the reality of the process became clear to those scrambling to apply only when they were met with this plethora of restrictions, delivered by embattled bank call-centre staff unable to provide the ‘over-spun’ offer due the restrictions placed upon them. It is for this reason, that up until this date, only 983 loans had been approved out of 130,000 applications.

    In fact, the Business Secretary stated, during the daily briefing on 1st April: “The Chancellor, together with the bank of England and the Financial Conduct Authority, wrote to the chief executives of the UK banks to urge them to make sure that the benefits of the loan scheme are passed through to businesses and consumers. And it would be completely unacceptable if any banks were unfairly refusing funds to good businesses in financial difficulty. Just as the taxpayer stepped in to help the banks back in 2008, we will work with the banks to do everything they can to repay that favour and support the businesses and people of the United Kingdom in their time of need.”

    This is an incredible exercise in finger-pointing from the government, especially as the banks had in fact been lobbying the government to fix the aforementioned requirements so that they could extend lending. They can now proceed without personal guarantees for loans of up to £250,000 – even if the government insists on spinning it as ‘banning’ the banks from doing so, rather than removing their restriction that they adhere to normal lending criteria. They can also now lend via the scheme without having to force the small business to attempt an application for a commercially available product first.

    Those who have already taken out a loan under the scheme will no-doubt welcome the statement that “this will apply to finance already offered under the scheme, to ensure that all business owners receive the same level of government protection.”

    Still, if you are considering taking out a loan, think hard about this.

    How was your business performing before the coronavirus outbreak? How is it likely to perform afterwards, when the face of the country has changed? Will the government jump in to deliver on their guarantee if you struggle with repayments three years from now, or will businesses have to have gone bankrupt in order for the government to deliver on their guarantee to lenders? I suspect the latter, so this business loan is all on you and your business.

    Is it a good idea to plug the hole for who-knows-how-long with a loan? Is it possible to temporarily suspend or cut-down your business activities rather than struggle on through? It’s your choice. Just, please, do not carry on with your business as if nothing is happening.

    (In fact, it’s an important note that you may even be benefiting from the new places money is flowing, if one of your business areas is suddenly valuable – do consider this if you haven’t already. You can make money in a crisis without ‘profiteering’, just by doing something valuable that people or businesses want to pay for right now. Just look at the online video-conferencing marketplace, for example.)

    Essentially, by taking out a loan to carry on through this, your business is absorbing some of the economic hurt of coronavirus by reducing your future earnings. Perhaps, if your revenue has been fundamentally reduced, then it is worth seriously considering suspending your business activities, furloughing your workers and signing yourself up for Universal Credit to come back in however many months time. You shouldn’t need to go bankrupt or close down completely to do this, but those options are of course always available.

    In fact, the British Business Bank page on the Coronovirus Business Interruption Loan quietly added the following statement on 15th April: “Lenders will need further information to confirm eligibility. All lending decisions remain fully delegated to the 40+ [since amended to 90 on 27th July and 100 on 24th September] accredited lenders” – presumably small businesses are unsure why their loan requests are being turned down given they believe they satisfy the requirements otherwise listed there: “Your business must: Be UK-based in its business activity; Have an annual turnover of no more than £45 million; Have a borrowing proposal which the lender would consider viable, were it not for the current pandemic; Self-certify that it has been adversely impacted by the coronavirus (COVID-19).” If lenders are turning down otherwise healthy businesses in need of the loan, according to their own additional proprietary criteria, this route may not even be guaranteed to be available to your business.

    Also, on 24th April, the British Business Bank quietly amended the eligibility criteria listed, namely highlighting the ineligibility of small businesses who “have been classed as a ‘business in difficulty’ on 31 December 2019, if applying to borrow £30,000 or more.”, though this restriction has since been removed on 30th July, whereby “smaller businesses with fewer than 50 employees and less than £9,000,000 in annual turnover and/or annual balance sheet will not be considered undertakings in difficulty unless they are (a) subject to collective insolvency procedure under national law, or (b) in receipt of rescue aid (which has not been repaid) or restructuring aid (and are still subject to a restructuring plan).”

    Details on the Coronavirus Business Interruption Loan can be found here: https://www.british-business-bank.co.uk/ourpartners/coronavirus-business-interruption-loan-scheme-cbils-2/for-businesses-and-advisors/

    It is worth noting that not only vanilla cash loans are available – overdrafts, invoice finance and asset finance are also included under this umbrella term.

    The deadline for applications has since been extended amid the November lockdown to 31st January 2021.

     

     

    Fancy some free labour?

    In July, the chancellor announced the Kickstart Scheme in his Plan for Jobs, but details were only finally announced on 2nd September.

    Employers can offer youngsters aged 16-24 who are claiming Universal Credit a six-month work placement” and “The government will fully fund each “Kickstart” job – paying 100% of the age-relevant National Minimum Wage, National Insurance and pension contributions for 25 hours a week.” plus “£1500 to set up support and training for people on a Kickstart placement, as well as helping pay for uniforms and other set up costs.

    The troubling caveat is that small businesses must team up to total 30 or more such placements before they can apply for the grant – a barrier that few larger businesses will struggle with.

    Nonetheless I strongly encourage all potential employers take up the offer. After all, your larger competition, with reduced barriers to receiving this support, probably will.

    Learn more from the press release and guidance.

     

     

    Regarding everybody with reduced earnings

     

    Universal Credit (or Tax Credits, if you already get them):

    This benefit is calculated using your actual income. This is true even if you have been in business for more than a year. (There was a restriction called the Minimum Income Floor that would have based your income calculation on the National Minimum Wage at a minimum, after 12-months. This restriction is removed until 30th April 2021.)

    Guidance can be found at https://www.understandinguniversalcredit.gov.uk/coronavirus/

    Also, Turn2Us offers a great benefits calculator, so consider running your anticipated earnings through that.

    The basic element of this (and of Working Tax Credits if you’re still on the older system) has gone up by £20 per week from 6th April along with the usual annual minor rise, which all claimants receive. I have been informed that for Working Tax Credits this will be first paid on 10th April, but will be backdated to 6th April.

    Also, “From April, Local Housing Allowance rates will be increased to the 30th percentile of market rents. This will apply to all private renters who are new or existing Universal Credit housing element claimants, and to existing Housing Benefit claimants.” but I find this highly misleading as many local authorities already used the 30th percentile of market rents.

    If you are already on Housing Benefit or getting the equivalent via Universal Credit, you can check the current LHA rates to see if 30% would represent a rise in the amount, here: https://lha-direct.voa.gov.uk/

    Applicable to those already claiming Tax Credits, an HMRC press release from 4th May states that “Tax credits customers will continue to receive payments even if working fewer hours due to COVID-19” also stating “These customers do not need to contact HMRC about this change. We will treat customers as working their normal hours until the Job Retention Scheme and Self-Employment Income Support Scheme close, even if they are not using either scheme.”

     

    Help with your home mortgage?

    Mortgage holidays are available for up to 6 months – ask your lender. A great reference can be found at monesysavingexpert.com including a summary of what’s on offer from which provider, as far as they know. And as they note: “You will still be charged interest – but it’s added to the total cost and you get short-term respite.”

    A FCA press release on the topic, from 2nd June, is also available here, and it guidance for beyond the applicable period (which ends 31st October 2020) was being considered since 26th August. Specifically, “firms should consider the appropriateness, and use, of a range of different short and long-term support options to reflect the specific circumstances of their customers. This could include extending the repayment term or restructuring of the mortgage. Where consumers need further short-term support, firms should offer arrangements for no or reduced payments for a specified period to give customers time to get back on track.”

    Due to the November lockdown, these protections were proposed to be extended, now confirmed, namely to “extend the availability of payment deferrals to support borrowers who are experiencing payment difficulties because of coronavirus. This will mean that: those who have not yet had a payment deferral will be eligible for 2 payment deferrals of up to 6 months in total [and] those who currently have an initial payment deferral, will be eligible for another payment deferral of up to 3 months [and] those who have resumed repayments after an initial payment deferral will be eligible for another payment deferral of up to 3 months”

     

    Help with your private rent?

    Landlords who have a buy-to-let mortgage can also benefit from a 3 month mortgage holiday, so contact your landlord if you need a rent holiday and hopefully than can pass this on. It is worth noting they were legally prevented from evicting you until at least 20th September, and until 31st March 2021 they will still have to give you 6 months notice.

     

    Help with your credit card or loan repayments?

    On 2nd April, the Financial Conduct Authority proposed temporary financial relief for customers impacted by coronavirus, later confirming those measures on 9th April. These measures include firms being expected to:

    “Offer a temporary payment freeze on loans and credit cards for up to three months, for consumers negatively impacted by coronavirus”

    “Allow customers who are negatively impacted by coronavirus and who already have an arranged overdraft on their main personal current account, up to £500 charged at zero interest for three months”

    “Make sure that all overdraft customers are no worse off on price when compared to the prices they were charged before the recent overdraft pricing changes came into force” (most banks had recently raised their overdraft interest rates to 39.9% in response to these changes)

    “Ensure consumers using any of these temporary payment freeze measures will not have their credit file affected”

    These measures have been specifically noted to include: “guarantor loans, logbook loans, home collected credit, a loan issued by Community Development Finance Institution and some loans issued by credit unions, but only where these are regulated. The guidance also applies to firms which have acquired such loans. These measures won’t replace normal forbearance rules where these would be more suitable for a consumer in serious and immediate financial difficulty”

    The press release on these confirmed measures can be found here and these measures are in effect as of 14th April, with additional measures since confirmed on 1st July.

    The next stage of these protections were proposed on 16th September (which would, for example, require firms to “give customers time and opportunity to repay and do not pressurise them into repaying their debt within an unreasonably short period of time”) and these were confirmed on 30th September.

    Since the November lockdown, these measures were again proposed to extend, since confirmed, in order to: “extend payment deferrals and other support to personal loans, credit cards, motor finance, rent-to-own, buy-now-pay-later and pawnbroking customers who are experiencing payment difficulties because of coronavirus. These proposals will mean that: those who have not yet had a payment deferral will be eligible for 2 payment deferrals of up to 6 months in total [and] those who currently have an initial payment deferral, will be eligible for a further payment deferral of up to 3 months”

     

    Help with motor finance and high-cost credit?

    On 17th April, the FCA announced “another proposed package of measures to directly support consumers facing payment difficulties due to coronavirus (Covid-19). The range of targeted temporary measures cover motor finance and high cost credit agreements, which include: high-cost short-term credit (including payday loans), buy-now pay-later (BNPL), rent-to-own (RTO) and pawnbroking.”

    In particular, regarding motor finance, the FCA expects firms “to provide a 3-month payment freeze to customers who are having temporary difficulties” taking care of some potential loop-holes in advance, such as ensuring firms “should not change customer contracts in a way that is unfair [… e.g.] firms should not try to use temporary depreciation of car prices caused by the coronavirus situation to recalculate Personal Contract Purchase (PCP) balloon payments at the end of the term”

    Also, the FCA proposed a “a 1 month interest-free payment freeze” on pay-day loans and a “3-month payment freeze” on buy-now pay-later (BNPL), rent-to-own (RTO) and pawnbroking agreements.

    These, now finalised, proposals came into force as of Monday 27th April, with additional measures since confirmed on 15th July.

    Since the November lockdown, these measures are again proposed to extend, in order to: “extend payment deferrals and other support to personal loans, credit cards, motor finance, rent-to-own, buy-now-pay-later and pawnbroking customers who are experiencing payment difficulties because of coronavirus. These proposals will mean that: those who have not yet had a payment deferral will be eligible for 2 payment deferrals of up to 6 months in total [and] those who currently have an initial payment deferral, will be eligible for a further payment deferral of up to 3 months”

     

    Help with your insurance costs?

    On 14th May, the FCA made a press release, “FCA confirms measures to help insurance customers who may be suffering financial difficulties as a result of coronavirus” – requiring firms to reassess the risk profile of customers as “there may be scope to offer customers materially lower premiums”, consider if there are other more suitable products to switch customers to e.g. “a motor insurance customer might no longer need associated add on cover such as key cover or could be moved from fully comprehensive cover to third party fire and theft”, and also waive cancellation fees and other fee associated with adjusting policies.

    “These actions could result in a reduction in the monthly premium for customers paying by instalments or a partial refund of the premium for customers who have paid up front. Where amendments to the insurance cover do not help alleviate the temporary payment difficulties for customers paying their premium in instalments, then the FCA expects firms to grant customers a payment deferral unless it is obviously not in the customer’s interests to do so.

    The payment deferral should be granted for a period of between 1 and 3 months, though firms can go beyond 3 months should they wish to do so, and it is in the customer’s interests.

    Customers should be able to request a payment deferral at any point during the period up to 18 August 2020 while the window for requesting a payment deferral is open.”

    Alternatives are listed where payment deferral is not considered appropriate and there is a continued expectation to consider lowering interest rates. The measures came into force on May 18th 2020. See the full press release here

     

    Help with childcare?

    We missed this when it was initially published on 7th May, and only added this section to our page after the update on 14th August:

    “Working parents or carers, who are eligible for Tax-Free Childcare or 30 Hours Free Childcare but have temporarily fallen below the minimum income requirement because of coronavirus, will continue to receive financial support until 31 October 2020.

    Critical workers who may exceed the income threshold for the 2020 to 2021 tax year, as a result of working more to play a vital role in tackling coronavirus, will continue to receive support this tax year.”

    This is because:

    “Temporary changes have been made to the eligibility criteria for Tax-Free Childcare and 30 hours free childcare, during coronavirus.

    The changes may affect you if you, or someone you live with, are:

    • on furlough
    • not able to work or you’re working less
    • self-employed
    • a critical worker”

    Check the guidance page if this is something you need to look into.

     

     

    Miscellaneous Items

     

    BIDs ballots delayed

    In case it affects you, Business Improvement District ballots are being delayed until at least December 2020, to allow local authorities to concentrate on more pressing matters.

     

    You’re probably not insured against this

    The guidance has been updated to reflect that the government has added COVID-19 to the list of ‘notifiable diseases’ (a technical category used by insurers and may be referenced in your insurance policy documentation) change the phrasing in a way to make it more clear that most are unlikely to be insured: “those businesses which have an insurance policy that covers government ordered closure and pandemics or government ordered closure and unspecified notifiable disease should be able to make a claim” and that “The effect of the government adding COVID-19 to its list of notifiable diseases is to ensure that businesses with unspecified notifiable disease cover are able to make a claim – subject to the terms and conditions in their policy”

    As always, check your specific policy. And if you can’t understand it, since insurance legalese is notoriously complex to comprehend, call your insurer.

    If you’re in the events industry, you might also like to note that “event cancellation policies that include unspecified notifiable disease extensions should be able to make a claim for the necessary and unavoidable cancellation, abandonment, curtailment, postponement and disruption of their event for reasons beyond the control of organisers and participants (subject to the other terms and exclusions of their policy)”

    Many small businesses had some form of ‘business interruption’ insurance policy that either explicitly did not apply or was sufficiently vague to be contested by their insurer. On 1st May the FCA made a press release stating the “FCA seeks legal clarity on business interruption insurance alongside package of measures to help consumers and small businesses […] The Financial Conduct Authority (FCA) has today announced it intends to seek legal clarity on business interruption (BI) insurance to resolve doubt for businesses who are facing uncertainty on their claims.” Mel Stride, chair of the Treasury Committee, has commented on this, calling the steps taken by FCA “extremely welcome” and stating that “The Committee will be pressing for rapid progress. Those who should be paid, should be paid as soon as possible.” So hopefully there will be some development soon for those awaiting to understand if their insurance policy should pay out.

    In fact, on 15th September the High Court handed down a ruling on this FCA test case regarding business interruption insurance, finding “in favour of the arguments advanced for policyholders by the FCA on the majority of the key issues.” However: “The judgment is complex, runs to over 150 pages and deals with many issues. […] The FCA’s legal team at Herbert Smith Freehills have published a summary on their website, which may be referred to for further detail.”

    This means some small businesses with Business Interruption insurance who were affected by this may yet receive the compensation for their losses they had hoped for under their policy. Legal wrangling is not yet over, however, as the High Court may yet be superceded by a successful appeal or ruling by the Supreme Court, which concluded hearing appeals on 23rd November. Whether a judgment will be handed down before Christmas remains to be seen. Nonetheless, you may want to revisit this with your insurer, where applicable.

    Also, on 13th May we learned that “Businesses with supply chains which rely on Trade Credit Insurance and who are experiencing difficulties maintaining cover due to Coronavirus will get support from the government, the Economic Secretary to the Treasury, John Glen has announced.” – see press release here

     

    ‘Wrongful trading’ rules suspended

    According to a recent daily briefing, and the associated HMRC press release at https://www.gov.uk/government/news/regulations-temporarily-suspended-to-fast-track-supplies-of-ppe-to-nhs-staff-and-protect-companies-hit-by-covid-19:

    “The government will also temporarily suspend the wrongful trading provisions to give company directors greater confidence to use their best endeavours to continue to trade during this pandemic emergency, without the threat of personal liability should the company ultimately fall into insolvency.”

    This will be “retrospectively from 1 March 2020 for three months” but the press release also notes:

    “Existing laws for fraudulent trading and the threat of director disqualification will continue to act as an effective deterrent against director misconduct.”

    The rule suspension has since been extended to 30th June.

     

    What support is there for charities?

    Acknowledging “there are nearly 170,000 charities in this country”, the Chancellor announced £750m of support for charities on 8th April, including hospices and those supporting domestic abuse victims, with £360 million direct from government departments and £370 million for smaller charities, including through a grant to the National Lottery Community Fund. The government will also match donations to the National Emergencies Trust as part of the BBC’s Big Night In fundraiser later this month – pledging a minimum of £20 million.

    No further detail is available as yet, beyond the news release, here:

    https://www.gov.uk/government/news/chancellor-sets-out-extra-750-million-coronavirus-funding-for-frontline-charities

     

    What support is there for startups?

    If your business is UK-incorporated, has raised £250k or more already from equity investment in the last 5 years, has none of its shares traded on a regulated market, multilateral trading facility or other listing venue, was incorporated on or before 31st December 2019 and either half or more employees are UK-based OR half or more revenues are from UK sales… Then the Future Fund may be worth considering, which “will provide government loans to UK-based companies ranging from £125,000 to £5 million, subject to at least equal match funding from private investors”

    Full details, including a Convertible Loan Agreement, are available on the fund’s guidance page. It opened to applications on 20th May and will remain available until 30th November.

     

    What support is there for the hospitality and tourism industries?

    On 9th July, the Eat Out to Help Out Scheme guidance was published. As we, at the time, have no clients in this industry, we’ve decided not to go into any detail here. The scheme ended on 31st August.

    Also, the VAT rate for these sectors was cut from 20% to 5% on 15th July and this has since been extended by the Winter Economy Plan to the end of March 2021.

     

     

    If these support measures don’t help? If you ‘slip through the cracks’?

    Unfortunately, many do. And even though the Treasury Select Committee has sustaining pressure on the Chancellor to address a list of gaps, as part of its “Economic impact of Coronavirus” inquiry, and additional support has been drawn up in some devolved administrations, no more help is currently expected in England.

    People who ‘slip through the cracks’ include Personal Service Companies paying their directors a mixture of salary and dividends, self-employed workers with over £50,000 in savings, graduates, people newly self-employed, people who were only added to the payroll after the 19th March cut-off etc.

    You can find out more about what the Treasury Select committee has suggested, here:

    https://committees.parliament.uk/committee/158/treasury-committee/news/145875/treasury-committee-urgent-action-needed-for-those-not-eligible-for-treasurys-support-measures/

    However, the Chancellor’s response will likely do little to fill you with confidence, as very little flexibility was shown: https://committees.parliament.uk/committee/158/treasury-committee/news/146064/chancellor-responds-to-treasury-committee-on-help-for-those-not-eligible-for-governments-support-measures/

    The Treasury Select Committee’s pressure continues, however: https://committees.parliament.uk/committee/158/treasury-committee/news/132806/committee-urges-chancellor-to-help-those-who-have-fallen-through-the-gaps-of-coronavirus-support/

     

    References

    The most up to date guidance and support documents for small businesses and employers, direct from gov.uk, can be found here:

    https://www.gov.uk/government/collections/financial-support-for-businesses-during-coronavirus-covid-19

    https://www.gov.uk/government/publications/guidance-to-employers-and-businesses-about-covid-19/guidance-for-employers-and-businesses-on-coronavirus-covid-19

    https://www.gov.uk/government/publications/winter-economy-plan/winter-economy-plan

    And, as lockdown measures are gradually phased back, a specific collection of guidance documents have been launched: “Working safely during coronavirus (COVID-19)” which you can find here: https://www.gov.uk/guidance/working-safely-during-coronavirus-covid-19

    But these documents leaves a lot of questions unanswered, which is why we will continue to monitor them, and other sources, as the help available expands and details on existing schemes emerge.

    The ‘Business Support Finder’ tool, to help find what support is available for your business, was launched on 20th April, here: https://www.gov.uk/business-coronavirus-support-finder

    Also, HMRC introduced a digital assistant to aid in finding information about Coronavirus support schemes on 2nd May. It can be found here: https://www.tax.service.gov.uk/ask-hmrc/virtual-assistant/support-for-coronavirus

    Also, the Business Support FAQ has been updated re coronavirus at https://www.businesssupport.gov.uk/faqs/, but it offers little new information. We will watch this document, also.

    A specific, better laid out site at https://www.businesssupport.gov.uk/coronavirus-business-support/ has now been launched – no new information there for now, but it easier to navigate and we’ll continue to monitor it.

    A similar resource, specifically focused on the Self-Employment Income Support Scheme, can be found here: https://www.businesssupport.gov.uk/self-employment-income-support-scheme-faqs/

    HMRC official guidance outlining the specific support they are offering has also been launched, including:

    https://www.gov.uk/guidance/claim-back-statutory-sick-pay-paid-to-employees-due-to-coronavirus-covid-19

    https://www.gov.uk/guidance/claim-a-grant-through-the-coronavirus-covid-19-self-employment-income-support-scheme

    https://www.gov.uk/guidance/check-if-you-could-be-covered-by-the-coronavirus-job-retention-scheme – for employees

    https://www.gov.uk/guidance/claim-for-wage-costs-through-the-coronavirus-job-retention-scheme – for employers

    https://www.gov.uk/government/publications/coronavirus-job-retention-scheme-step-by-step-guide-for-employers – a step-by-step guide for employers

    https://www.gov.uk/guidance/claim-for-wages-through-the-coronavirus-job-retention-scheme – the online portal

    https://www.gov.uk/government/publications/coronavirus-job-retention-scheme-service-availability-and-issues/coronavirus-job-retention-scheme-service-availability-and-issues – the online portal service availability checker

    https://www.gov.uk/guidance/work-out-80-of-your-employees-wages-to-claim-through-the-coronavirus-job-retention-scheme – the calculator for employers to work out what they can claim (for most but not all situations)

    The CBI webinar in which Ben Kerry, Head of Labour Markets, HMT, first revealed that limited company directors could claim under the Coronavirus Job Retention Scheme for their PAYE earnings: https://www.cbi.org.uk/articles/daily-coronavirus-webinar-job-retention-scheme-27-03-2020/ (time stamp 27:20)

    https://www.gov.uk/guidance/deferral-of-vat-payments-due-to-coronavirus-covid-19

    And the announcement of a tax helpline to support businesses affected by coronavirus – 0800 024 1222 – details on this can be found here: https://www.gov.uk/government/news/tax-helpline-to-support-businesses-affected-by-coronavirus-covid-19

    If you think you can help during this national time of need, see this page: https://www.gov.uk/coronavirus-support-from-business

    The HMRC press release that notes the intention for ‘wrongful trading’ rules to be suspended, can be found here: https://www.gov.uk/government/news/regulations-temporarily-suspended-to-fast-track-supplies-of-ppe-to-nhs-staff-and-protect-companies-hit-by-covid-19

    The Coronavirus Business Interruption Loan scheme details are most thoroughly outlined here: https://www.british-business-bank.co.uk/ourpartners/coronavirus-business-interruption-loan-scheme-cbils-2/for-businesses-and-advisors/

    Coronavirus Large Business Interruption Loan scheme details via Business Support FAQs: https://www.businesssupport.gov.uk/coronavirus-large-business-interruption-loan-scheme/

     

     

    How the advice has changed

    Material changes to gov.uk advice and guidance documents:

    2nd December

    The new deferred VAT repayment scheme guidance was updated to state that “You cannot opt in yet. The online opt in process will be available in early 2021. You must opt in yourself, your agent cannot do this for you.” – if applicable, you can opt in until the end of March 2021.

    1st December

    Guidance was updated to reflect that it is now past the deadline for claims regarding October via the older Coronavirus Job Retention Scheme.

    30th November

    The third iteration of the Self Employment Income Support Scheme grant opened for applications, with staggered availability for individuals over the first week, as per prior such grants.

    25th November

    The Chancellor delivered his Spending Review 2020 speech, though no major items needed calling out in this document.

    24th November

    New guidance was published entitled “How your trading conditions affect your eligibility for the Self-Employment Income Support Scheme”. In addition to the previous eligibility criteria: “To be able to claim for the third grant, you must either: be currently trading but are impacted by reduced demand due to coronavirus [or] have been trading but are temporarily unable to do so due to coronavirus. You must also: intend to continue to trade [and] reasonably believe there will be a significant reduction in your trading profits due to reduced demand or your inability to trade”

    Regarding the ‘reduced demand’ criterion, note that “You must not claim if the only impact on your business is increased costs. For example, if you have had to purchase face masks and cleaning supplies. This would not be considered as reduced activity, capacity or demand.”

    Regarding the ‘significant reduction in your trading profits’ criterion, no objective measure is provided, instead only stating that “HMRC expects you to make an honest assessment about whether you reasonably believe your business will have a significant reduction in profits” and “HMRC cannot make this decision for you because your individual and wider business circumstances will need to be considered when deciding whether the reduction is significant. You should wait until you have a reasonable belief that your trading profits are going to be significantly reduced, before you make your claim.”

    The main SEISS guidance also states: “You must keep evidence that shows how your business has been impacted by coronavirus resulting in less business activity than otherwise expected”, that “You must make your claim on or before 29 January 2021” and “To make a claim for the third grant your business must have been impacted by coronavirus on or after 1 November 2020.”

    For those comfortable with legalese, the Treasury direction made by the Chancellor brings the most precise wording:

    “4.1. A claim for a payment under SEISS 3 (a “SEISS 3 payment”) must be made in accordance with paragraph 3 of SEISS on or before 29 January 2021.

    4.2. Subject to paragraph 4.3, a claim may only be made for a SEISS 3 payment in respect of the period beginning on 1 November 2020 and ending on 29 January 2021 (“the qualifying period”) in relation to a trade—

    (a)the business of which has suffered reduced activity, capacity or demand in that period from that which could reasonably have been expected but for the adverse effect on the business of coronavirus or coronavirus disease, and

    (b)which the claimant reasonably believes will suffer a significant reduction in trading profits for a relevant basis period from that which would otherwise have reasonably been expected as a result of that reduced activity, capacity or demand.

    4.3. A claim cannot be made under paragraph 4.2 in relation to any reduced activity, capacity or demand caused solely because the person is required to self-isolate, or care for a person required to self-isolate, as a result of travelling to the United Kingdom.

    4.4. On a claim by a relevant person, paragraphs 7 (profits condition) and 9 (relevant income for relevant reservists) of SEISS Extension apply in determining whether the person is a qualifying person for the purposes of the claim.

    4.5. For the purposes of paragraph 4.2—

    “relevant basis period” means a basis period or basis periods in which the qualifying period falls;

    “basis period” has the same meaning as in Chapter 15 of Part 2 of ITTOIA 2005.”

     

    For most, the “relevant basis period” referred to here will be the 2020/21 tax year.

    The examples given can help to illustrate the intention of these new criteria.

    Our interpretation is that you must be able to confidently predict that your profits from your self-employed trade (ignoring any other kinds of income you receive) will be significantly (however you feel you can justifiably interpret the meaning of ‘significantly’) down for this tax year, at the time you claim, and you must keep evidence to that effect. If, as a client of ours, you receive a monthly report from us, you can use it to help you, as we will provide the current forecast profit to aid in your decision-making.

    23rd November

    The British Business Bank added clarification regarding CBILS loan terms: “Following the Chancellor’s announcement on his “plan to extend the government guarantee on these loans for up to ten years, making it easier for lenders to give people more time to repay.” The British Business Bank (BBB) will continue to work with Her Majesty’s’ Government in respect of any extension to the Guarantee. The BBB currently envisages any extension (beyond the current 6-year tenure for CBILS facilities) would relate to the provision of forbearance only.”

    The Treasury Select Committee wrote to the Chancellor, urging him once again “to help those who have fallen through the gaps of coronavirus support”, noting in particular that “concerns in the first report of our inquiry into the economic impact of coronavirus, Gaps in Support, have not been addressed. There are still many who are excluded from both these schemes through no fault of their own.” For example, noting that “the Scottish Government has set up a Newly Self-Employed Hardship Fund administered by local authorities […] the Northern Ireland Executive has set up an Individuals Emergency Resilience Programme and ring-fenced some further amounts to assist individual artists/freelancers in the arts industry [and has] set up a Covid Restrictions Business Support Scheme [that] aims to help small businesses that do not have premises, such as driving instructors, mobile hairdressers, and also businesses, such as cleaners and caterers, that have not been forced to close but act as part of the supply chain to businesses forced to close”

    The UK Supreme Court concluded hearing appeals in connection with the Financial Conduct Authority’s test case on business interruption insurance. Whether a judgment will be handed down before Christmas remains to be seen.

    20th November

    A new scheme for repaying previously deferred VAT was added to the guidance, stating that “Instead of paying the full amount by the end of March 2021, you can make up to 11 smaller monthly instalments, interest free. All instalments must be paid by the end of March 2022.” Note also that “If you opt in to the scheme, you can still have a time to pay arrangement for other HMRC debts and outstanding tax.” – see the Pay VAT deferred due to coronavirus (COVID-19) guidance document for more details


    19th November

    Coronavirus Job Retention Scheme guidance was updated to provide advice for furloughing employees from November, with details largely corresponding to those previously reported in various statements and announcements. As before, “salaried company directors are eligible to be furloughed and receive support through this scheme.” HMRC also added more detail to what they will publish regarding claimants, stating in their guidance directed toward affected employees: “As part of HMRC’s commitment to transparency and to deter fraudulent claims, we will publish information about employers who claim for periods starting on or after 1 December 2020. The following information will be published on GOV.UK: the employer name, an indication of the value of the claim, the company number for companies and Limited Liability Partnerships (LLPs). Further detail on how HMRC will give an indication of the value of the claim will be available from late November. HMRC will also be improving the information available to you by including details of claims made for you, for claim periods starting on or after 1 December 2020 in your Personal Tax Account on GOV.UK”

    Previously announced support for consumer credit customers by FCA was confirmed.


    17th November

    Previously announced support for mortgage borrowers by FCA was confirmed.

    13th November

    Regarding the extended Coronavirus Job Retention Scheme, HMRC revealed in their guidance that “HMRC will publish employer names, an indication of the value of the claim and, for companies and Limited Liability Partnerships (LLPs) the company registration number of those who have made claims under the scheme for the month of December onwards. Further detail on how HMRC will give an indication of the value of the claim will be available from late November.”

    6th November

    Bounce Back Loan guidance was updated to reflect the newly extended application deadline of 31st January 2021, and noting that “If you already have a Bounce Back Loan but borrowed less than you were entitled to, you can top up your existing loan to your maximum amount. You must request the top-up by 31 January 2021”. The number of participating lenders was increased from 11 to 28, and an addition was also made to say that: “Before your first repayment is due, your lender will contact you about further options to: extend the term of your loan to 10 years; move to interest-only repayments for a period of 6 months (you can use this option up to 3 times); pause your repayments for a period of 6 months if you have already made at least 6 repayments (you can use this option once)”

    5th November

    Rishi Sunak addressed parliament to announce the extension of the Coronavirus Job Retention Scheme to the end of March 2021, reviewing the need for it to continue in January. As a result, both the previously planned Job Support Scheme and the Job Retention Bonus that would have been due to be paid in February are indefinitely postponed. Also announced was a comparable increase in the next Self Employment Income Support Scheme grant to a full 80% of monthly average earnings for three months, paid in a single instalment capped at £7,500. – See the press release or fact sheet for more details.

    4th November

    The FCA proposed that to “extend payment deferrals and other support to personal loans, credit cards, motor finance, rent-to-own, buy-now-pay-later and pawnbroking customers who are experiencing payment difficulties because of coronavirus. These proposals will mean that: those who have not yet had a payment deferral will be eligible for 2 payment deferrals of up to 6 months in total [and] those who currently have an initial payment deferral, will be eligible for a further payment deferral of up to 3 months”

    3rd November

    The Government extended the extra welfare support for self-employed for a further six months. The Minimum Income Floor is usually applied for Self-Employed individuals claiming Universal Credit. The income figures used for calculating award amounts have a minimum equivalent to the National Minimum Wage for businesses more than a year old. This rule was suspended in March, but was due to resume on 12th November. It has now been suspended until the end of April 2021.

    2nd November

    Guidance about the Self-Employment Income Support Scheme Grant Extension has been updated – the grant is now increased from the previous 40% to 55% of average monthly profits (roughly equivalent to one month at 80% – on par with the also-extended Coronavirus Job Retention Scheme – and two months at 40% as previously planned). The online service will be available from 30 November 2020, as opposed to the originally planned 14th December date, and “HMRC will provide full details about claiming and applications in guidance on GOV.UK in due course.” Eligibile individuals must “declare that they intend to continue to trade and either: are currently actively trading but are impacted by reduced demand due to coronavirus [or] were previously trading but are temporarily unable to do so due to coronavirus” Disparity in support compared to for employed individuals continues, however, as to be eligible individuals must “have been previously eligible for the Self-Employment Income Support Scheme first and second grant (although they do not have to have claimed the previous grants)” whereas the newly extended CJRS scheme is open to new employees. For example, those those who started self-employment in May 2019 continue to have no SEISS support, though someone first paid in their new employment on 30th October 2020 may be furloughed under CJRS in November.

    Also, as per the press release, “government loan schemes […] have been extended to the end of January, while firms can ‘top up’ existing Bounce Back Loans should they need additional finance”

    In line with the previous statement from the Prime Minister on 31st October, the FCA proposed help for mortgage borrowers, specifically to “extend the availability of payment deferrals to support borrowers who are experiencing payment difficulties because of coronavirus. This will mean that: those who have not yet had a payment deferral will be eligible for 2 payment deferrals of up to 6 months in total [and] those who currently have an initial payment deferral, will be eligible for another payment deferral of up to 3 months [and] those who have resumed repayments after an initial payment deferral will be eligible for another payment deferral of up to 3 months”

    31st October

    The Prime Minister announced a series of measures, to compliment a November lockdown proceeding from Thursday 5th. “The Coronavirus Job Retention Scheme has been extended for a month with employees receiving 80% of their current salary for hours not worked and further economic support announced.” An important note is that “Neither the employer nor the employee needs to have previously used the CJRS […] To be eligible to be claimed for under this extension, employees must be on an employer’s PAYE payroll by 23:59 30th October 2020. This means a Real Time Information (RTI) submission notifying payment for that employee to HMRC must have been made on or before 30th October 2020. […] Employers can claim the grant for the hours their employees are not working, calculated by reference to their usual hours worked in a claim period. Such calculations will broadly follow the same methodology as currently under the CJRS. When claiming the CJRS grant for furloughed hours, employers will need to report and claim for a minimum period of 7 consecutive calendar days. […] Employers will pay employer NICs and pension contributions, and should continue to pay the employee for hours worked in the normal way. […] The Government will confirm shortly when claims can first be made in respect of employee wage costs during November, but there will be no gap in eligibility for support between the previously announced end-date of CJRS and this extension.”

    Also: “Mortgage payment holidays will no longer end today. Borrowers who have been impacted by coronavirus and have not yet had a mortgage payment holiday will be entitled to a six month holiday, and those that have already started a mortgage payment holiday will be able to top up to six months without this being recorded on their credit file.” and “Businesses required to close in England due to local or national restrictions will be eligible for the following: For properties with a rateable value of £15k or under, grants to be £1,334 per month, or £667 per two weeks; For properties with a rateable value of between £15k-£51k grants to be £2,000 per month, or £1,000 per two weeks; For properties with a rateable value of £51k or over grants to be £3,000 per month, or £1,500 per two weeks.”

    28th October

    SSP guidance was updated to reflect that employers can ask employees to provide a ‘shielding note’ or a letter from their doctor or health authority advising them to shield because they’re at high risk of severe illness from coronavirus.

    22nd October

    The Chancellor announced a plan to offer greater support to businesses in Tier 2 areas, not forced to close but subject to restrictions, saying they will be “providing enough funding to give every business premise in the hospitality, leisure and accommodation sectors a direct grant worth up to £2,100 – for every month Tier 2 restrictions apply. And that’s equivalent to 70% of the value of the grants available for closed businesses in Tier 3. And crucially, I am pleased to confirm these grants will be retrospective. Businesses in any area which has been under enhanced restrictions can backdate their grants to August.” though it is “up to local authorities to decide how best to distribute the grants”. The Chancellor also announced changes to the Job Support Scheme, stating that “under the original scheme, employees had to work for 33% of their normal hours. Now, we will ask them to work only 20% of their hours. Second, the employer contribution for the hours not worked will not be 33%, as originally planned, or even 20% as it is in the October furlough scheme – it will reduce to 5%. And the scheme will apply to eligible businesses in all alert levels” An increase reflected in changes to the Self Employment Income Support Scheme, too, “doubling the next round of the self-employed income support from 20% to 40% of people’s incomes, increasing the maximum grant to £3,750.”

    Guidance for the Self Employment Income Support Scheme Grant Extension was updated accordingly, along with a press release outlining all the changes announced, a factsheet for the newly titled ‘Job Support Scheme Open’ and a Local Restrictions Support Grant (Tier 2) factsheet for details on these schemes.

     

    21st October

    In lieu of an actual Autumn Budget, the Chancellor announced “a one-year Spending Review in order to prioritise the response to Covid-19, and our focus on supporting jobs” focusing on Providing departments with the certainty they need to tackle Covid-19 and deliver our Plan for Jobs to support employment; Giving our vital public services enhanced support to continue to fight against the virus alongside delivering first class frontline services; and Investing in infrastructure to deliver our ambitious plans to unite and level up the country, drive our economic recovery and Build Back Better. – the review is targeted to conclude in November.

     

    20th October

    The second Self Employment Income Support scheme closed to new applications on 19th October, with many guidance documents updated to reflect this. This was also the deadline for telling HMRC about any overpayments of this grant without incurring any penalty – see here for details.

    Martin Lewis of moneysavingexpert.com pressed HMRC into a written statement highlighting the availability of the full working from home allowance for anyone who had worked for home for any duration this tax year: “We recognise that the working from home situation is very fluid this year, so we’re accepting claims for the full year’s expenses. That includes even if people have only worked from home for some of the year, to avoid needing to contact us if you have to work from home again.”

     

    9th October

    The Chancellor announced that the Job Support Scheme will be expanded from 1st November to provide two-thirds salary up to a maximum of £2,100 a month, with only national insurance and pension contributions to be provided by the employer, for employees who cannot work for a minimum of 7 consecutive days as their firms premises have been “legally required to shut for some period over winter as part of local or natinoal restrictions”. The claims service will not open until early December, however. Also, the previous cash grant for businesses closed in local lockdowns is also increased, eligible after only two weeks of closure rather than three: “Small businesses with a rateable value of or below £15,000 can now claim £1,300 per month; medium sized businesses with a rateable value between £15,000 and £51,000 can claim £2,000 per month; and larger businesses can claim £3,000.” No mention is yet made about any change to the amounts previously available via discretionary local authority funds for businesses affected by closures but not on rates lists.

     

    6th October

    The BBC reported that “Of the 28 accredited lenders on the bounce back loan site, only two appear to offer loans to non-customers: peer-to-peer site Funding Circle, and Capital on Tap.” No high street banks are currently offering the ability to apply to non-customers as HSBC, the last such bank, “closed its doors to new customers last week.” This has locked out many small businesses from applying for such help, which is of particular concern since “The deadline for bounce back loan applications is 30 November, which means time is running out for firms who have yet to secure a loan.”

     

    2nd October

    It was announced that 30th November will be the last day you can claim for wages through the Coronavirus Job Retention Scheme for periods ending on or before 31st October 2020. “After this date you will not be able to submit any further claims or add to existing claims.”


    1st October

    The Treasury Select Committee asked the Chancellor to “confirm arrangements for devolved administrations following Budget delay” – typically the autumn budget allows the devolved administrations sufficient time to prepare for their own end of financial year. You may recall that the autumn budget was also cancelled in 2019, ostensibly due to Brexit, making this two years in a row that those in devolved adminstrations have been at a disadvantage to Westminster.

    HMRC extended the tax liability limit for the ‘Time To Pay’ service from £10k to £30k for those who complete Self Assessments so that “customers could pay their deferred payment on account bill from July 2020, any outstanding tax owed for 2019 to 2020 and their first payment on account bill for this current tax year in monthly instalments, up to 12 months, via this self-serve tool.” Noting in particular that “HMRC estimates around 95% of Self Assessment customers who are due to make payments on 31 January 2021 could qualify to implement a Time to Pay arrangement using the self-serve Time to Pay facility online, without needing to speak to an HMRC adviser.” – but also be advised that “the payment plan needs to be set up no later than 60 days after the due date of a debt”

     

    30th September

    FCA proposals for the “next stage of support for consumer credit and overdraft customers” were confirmed

     

    25th September

    In response to Rishi Sunak’s announcement on VAT repayments, the guidance on VAT deferral was updated to say that “businesses who deferred VAT due from 20 March to 30 June 2020 will now have the option to pay in smaller payments over a longer period.” In particular: “Instead of paying the full amount by the end of March 2021, you can make smaller payments up to the end of March 2022, interest free. You will need to opt-in to the scheme, and for those who do, this means that your VAT liabilities due between 20 March and 30 June 2020 do not need to be paid in full until the end of March 2022. Those that can pay their deferred VAT can still do so by 31 March 2021. […] More information on the scheme will be available on GOV.UK in the coming months.”


    24th September

    The chancellor announced the Winter Economy Plan, including a new Job Support Scheme (replacing the Coronavirus Job Retention Scheme) whereby “employers will continue to pay the wages of staff for the hours they work – but for the hours not worked, the government and the employer will each pay one third of their equivalent salary. […] employees must be working at least 33% of their usual hours. The level of grant will be calculated based on employee’s usual salary, capped at £697.92 per month.” and an extension of Self Employment Income Support Scheme (see below), along with a “15% VAT cut for the hospitality and tourism sectors” (though this had already been in effect since 15th July) and “help for businesses in repaying government-backed loans” plus for those who deferred their VAT bills, they “will be given more breathing space through the New Payment Scheme, which gives them the option to pay back in smaller instalments. Rather than paying a lump sum in full at the end March next year, they will be able to make 11 smaller interest-free payments during the 2021-22 financial year.” Additionally, there will be a “12-month extension from HMRC on the “Time to Pay” self-service facility, meaning payments deferred from July 2020, and those due in January 2021, will now not need to be paid until January 2022.” Regarding loans, “a new Pay as You Grow flexible repayment system” was announced “extending the length of the loan from six years to ten, which will cut monthly repayments by nearly half. Interest-only periods of up to six months and payment holidays will also be available to businesses.” The deadline for the Coronavirus Business Interruption Loan Scheme, the Coronavirus Large Business Interruption Loan Scheme, the Bounce Back Loan Scheme and the Future Fund are all now aligned to 30th November.

    The Self-Employment Income Support Scheme grant extension “is for self-employed individuals who are currently eligible for the Self-Employment Income Support Scheme and are actively continuing to trade, but are facing reduced demand due to coronavirus (COVID-19).” and it will “provide two grants and will last for six months, from November 2020 to April 2021. Grants will be paid in two lump sum instalments each covering a three-month period. The first grant will cover a three-month period from the start of November until the end of January. HMRC will provide a taxable grant covering 20 per cent of average monthly trading profits, paid out in a single instalment covering 3 months’ worth of profits, and capped at £1,875 in total. […] The second grant will cover a three-month period from the start of February until the end of April. HMRC will review the level of the second grant and set this in due course.”

    The Winter Economy Plan detail also further revealed that “Business affected by local restrictions can claim up to £500 for each week they are required to close.”

    Job Support Scheme specifics detailed to date show that “Large businesses will have to meet a financial assessment test, so the scheme is only available to those whose turnover is lower now than before experiencing difficulties from Covid-19. There will be no financial assessment test for small and medium enterprises (SMEs).” and also that “Employees must be on an employer’s PAYE payroll on or before 23 September 2020. […] Employers will be able to make a claim online through Gov.uk from December 2020”

    The CBILS scheme page was updated to reflect that it is available for SMEs through more than 100 accredited lenders across the UK (previously 90)

     

    20th September

    The government announced that “People will be required by law to self-isolate from 28 September, supported by payment of £500 for those on lower incomes who cannot work from home and have lost income as a result.”


    16th September

    SSP rules were updated to reflect that you may now reclaim SSP paid to employees for those who “have been notified by the NHS to self-isolate before surgery for up to 14 days” if the period of sickness started on or after 26th August 2020, noting “Most people are asked to self-isolate for 3 days before surgery. In this case, the day of surgery will be the 4th day of their period of incapacity for work. You cannot claim repayment of SSP for the day of surgery or any other days when the absence is not due to coronavirus.”

    The FCA announced “proposals to ensure that firms provide tailored support for users of consumer credit and overdraft products who continue to face payment difficulties due to coronavirus (Covid-19).” which would, for example, require firms to “Give customers time and opportunity to repay and do not pressurise them into repaying their debt within an unreasonably short period of time.”

    “Commercial tenants will be protected from the risk of eviction until the end of 2020 helping businesses to protect jobs.” – We missed it at the time, adding it here on 21st October – see original press release

     

    15th September

    The High Court handed down a ruling on the FCA test case regarding business interruption insurance, finding “in favour of the arguments advanced for policyholders by the FCA on the majority of the key issues.” However: “The judgment is complex, runs to over 150 pages and deals with many issues. […] The FCA’s legal team at Herbert Smith Freehills have published a summary on their website, which may be referred to for further detail.” This means some small businesses with Business Interruption insurance who were affected by this may yet receive the compensation for their losses they had hoped for under their policy. Legal wrangling may not yet be over, however.

     

    14th September

    The FCA published “additional guidance for firms, to ensure that consumers who have benefitted from payment deferrals under the current guidance who still face financial difficulties, as well as those whose financial situation may be newly affected by coronavirus after the current guidance ends, continue to get the support they need. […] The FCA’s current guidance published in June will continue to provide support for those impacted by coronavirus until 31 October 2020 – with consumers able to take a first or second three-month payment deferral until this date. The June guidance is due to expire on 31 October and we do not intend to extend this guidance. The guidance published today ensures consumers will still be able to obtain the support they need from their lenders after their payment holiday ends or they are newly affected by coronavirus after 31 October. However, we will keep the guidance under review and if circumstances change significantly, consideration will be given to any further measures that may be needed to support consumers during the ongoing pandemic.”

     

    11th September

    The Treasury Select Committee urged the chancellor to “carefuly consider” targeted extensions to the Job Retention Scheme

     

    9th September

    Ministers announced new grants of up to £1,500 every three weeks for businesses forced to close due to a ‘local lockdown’, to be distributed by local authorities – £1,500 for businesses with a rateable value of £51,000 or above; £1,000 for businesses with a rateable value below this; Anything up to £1,500 for businesses affected by closures but not on the business rates list, according to the discretion of the local authority.

     

    2nd September

    The Kickstart Scheme details were finally announced, whereby “employers can offer youngsters aged 16-24 who are claiming Universal Credit a six-month work placement” and “The government will fully fund each “Kickstart” job – paying 100% of the age-relevant National Minimum Wage, National Insurance and pension contributions for 25 hours a week.” plus “£1500 to set up support and training for people on a Kickstart placement, as well as helping pay for uniforms and other set up costs.” – The only caveat is that small businesses must team up to total 30 or more such placements before they can apply for the grant. Learn more from the press release and guidance

     

    26th August

    The FCA has proposed new guidance for mortgage payers in difficulty beyond 31st October 2020 (when the current guidance will end). Specifically, “firms should consider the appropriateness, and use, of a range of different short and long-term support options to reflect the specific circumstances of their customers. This could include extending the repayment term or restructuring of the mortgage. Where consumers need further short-term support, firms should offer arrangements for no or reduced payments for a specified period to give customers time to get back on track.”

     

    21st August

    “The ban on evictions extended for another 4 weeks and new 6 month notice periods to be in place until at least 31 March 2021.” – We missed it at the time, adding it here on 21st October – see original press release

     

    17th August

    The second Self Employment Income Support Scheme grant application opened: “If you’re eligible and your business has been adversely affected on or after 14 July 2020, you must make your claim for the second grant on or before 19 October 2020.” – Note that the date that the application is open for each particular person may differ as it appears to be staggered, like last time, so upon logging in you may find you may not yet actually apply until another day later this week. A separate page was also published to help you ‘Decide if your business has been adversely affected for the Self-Employment Income Support Scheme’. A press release today incorrectly states “Anyone whose self-employed business has been adversely affected by coronavirus since 14 July is eligible for the scheme.” but then goes on to state more accurately that “The eligibility criteria remains the same as for the first grant…

     

    14th August

    The guidance around the availability of tax-free childcare and 30 hours free childcare during coronavirus was updated – we missed the first publication of this advice on 7th May and so only just added it to this page today. In particular: “Working parents or carers, who are eligible for Tax-Free Childcare or 30 Hours Free Childcare but have temporarily fallen below the minimum income requirement because of coronavirus, will continue to receive financial support until 31 October 2020. Critical workers who may exceed the income threshold for the 2020 to 2021 tax year, as a result of working more to play a vital role in tackling coronavirus, will continue to receive support this tax year.”

     

    13th August

    HMRC published a policy paper entitled ‘How HMRC deals with and supports customers who have a tax debt’, which may be of use in particular if COVID-19 has resulted in getting behind with tax payments (other than 31st July 2020’s payment on account, which has an automatically adjusted due date of 31st January 2021)

     

    3rd August

    The Coronavirus Job Retention Scheme guidance page has had the old details on eligibility due to employment dates around the February-March removed, since “From 1 July you are eligible to be claimed for under the scheme, if your employer has previously submitted a claim for you in relation to a furlough period of at least 3 consecutive weeks taking place any time between 1 March 2020 and 30 June.” Details about the minimum furlough period were also removed, and the changes effective from 1st August were added.

     

    1st August

    The Coronavirus Job Retention Scheme rules changed: “Unless you’re making a new claim for an employee who is a military reservist or is returning from statutory parental leave, you can only continue to claim through the scheme if: you have previously furloughed the employee for 3 consecutive weeks between March 1 and 30 June; you submitted your claim before 31 July”

    The SSP rules changed such that clinically extremely vulnerable individuals who were previously advised to shield are no longer entitled to SSP – We missed this at the time as there was little publication or promotion of the fact (as far as we can tell it was only revealed in parliament by the Minister for Disabled People, Justin Tomlinson, in response to a written question on 29th June) and added this entry on 6th October 2020.

     

    31st July

    Job Retention Bonus details were published, whereby “An employer will be able to claim the Job Retention Bonus for any employees that were eligible for the Coronavirus Job Retention Scheme and they have claimed a grant for” provided they “have been continuously employed by the relevant employer from the time of the employer’s most recent claim for that employee until at least 31 January 2021” and “have been paid an average of at least £520 a month between 1 November 2020 and 31 January 2021”. For each of these qualifying employees, employers will be able to claim £1,000 (taxable) through GOV.UK from February 2021. Company directors are explicitly included in this scheme.

     

    30th July

    Criteria around the classifications of ‘businesses in difficulty’ regarding the Coronavirus Business Interruption Loan scheme changed, specifically such that now “smaller businesses with fewer than 50 employees and less than £9,000,000 in annual turnover and/or annual balance sheet will not be considered undertakings in difficulty unless they are (a) subject to collective insolvency procedure under national law, or (b) in receipt of rescue aid (which has not been repaid) or restructuring aid (and are still subject to a restructuring plan).” Therefore, lenders can now offer loans to these small businesses.

     

    28th July

    Self Employment Income Support Scheme guidance pages added information about what to do if you were not eligible for the grant or have been overpaid, with a fact sheet also available.

     

    27th July

    This week, the British Business Bank updated its Coronavirus Business Interruption Loan Scheme page to reflect that now 90 lenders are offering loans under the scheme, a significant increase against the previous figure of 40.

     

    23rd July

    The Treasury Committee chair commented on the government’s response to the interim report regarding ‘Gaps in Support’, whereby the chancellor gave the strong impression that no further measures are likely to be under consideration. The chair commented: “The Chancellor said that the schemes were designed to be open and accessible to as many people as possible, but the Committee remains to be convinced that more people could not have been helped.”

     

    15th July

    The FCA confirmed “further support for motor finance and high-cost credit customers”

     

    14th July

    Self Employment Income Support Scheme guidance was updated to confirm that the online service for the first grant is closed. Further information was included about the second and final grant. In addition to this advertised change, the following amendments were also quietly made:
    – The following statement was added: “You must keep evidence to confirm your business was adversely affected at the time you made your claim.”
    – The statement “You should not claim the grant if you’re a limited company or operating a trade through a trust.” was changed to “You cannot claim the grant if you trade through a limited company or a trust.” – it is not immediately clear if this represents a material change in position for those who e.g. have recently incorporated or have multiple trades.

     

    9th July

    The Eat Out to Help Out Scheme guidance was published. As we, at the time, have no clients in this industry, we’ve decided not to monitor it.

     

    8th July

    The Job Retention Bonus was announced. More information can be found in the government’s Plan for Jobs.

    The guidance page ‘Defer your Self Assessment payment on account due to coronavirus (COVID-19)’ was updated to clarify the situation regarding letters sent out to the self-employed: “The June 2020 Self Assessment statements showed 31 January 2021 as the due date for paying the July 2020 Payment on Account. This is because HMRC updated their IT systems to prevent customers incurring late payment interest on any July 2020 Payment on Account paid between 1st August 2020 and 31 January 2021. The deferment has not been applied for all customers by HMRC and it remains optional.” However, recall that “You do not need to tell HMRC that you’re deferring your payment on account.” so it continues to be the case that you may defer that payment, if you wish.

     

    3rd July

    The FCA announced “proposals to further support motor finance and high cost credit customers”

     

    2nd July

    – In regard to the Self Employment Income Support Scheme, new examples for how a business could be adversely affected by coronavirus were added. The section now reads:

    “Your business could be adversely affected by coronavirus if, for example:
    • you’re unable to work because you:
    ◦ are shielding
    ◦ are self-isolating
    ◦ are on sick leave because of coronavirus
    ◦ have caring responsibilities because of coronavirus
    • you’ve had to scale down, temporarily stop trading or incurred additional costs because:
    ◦ your supply chain has been interrupted
    ◦ you have fewer or no customers or clients
    ◦ your staff are unable to come in to work
    ◦ one or more of your contracts have been cancelled
    ◦ you had to buy protective equipment so you could trade following social distancing rules”

    Though this list is not intended to be exhaustive.

     

    1st July

    Coronavirus Job Retention Scheme guidance page updated with information on eligibility for claims before 1 July 2020. Also added new information on holiday pay that tells employers that flexibly furloughed employees can be recorded as on furlough during time spent on holiday.

    Also, the FCA “confirmed the support users of certain consumer credit products will receive if they are still experiencing temporary payment difficulties due to coronavirus (Covid-19).”

     

    30th June

    The VAT payment deferral period ended: “If you have cancelled your Direct Debit to HMRC to take advantage of the deferral, you will need to set up a new Direct Debit arrangement in time for the first payment after 30 June. Payments due after 30 June must be paid in full as normal and you must continue to file your VAT return on time. […] If you chose to defer your VAT payment as a result of coronavirus, you must pay the VAT on or before 31 March 2021. You can pay or make payments towards your deferred VAT now or at any time up to 31 March 2021.”

     

    25th June

    Though only the ‘TUPE regulations’ changes to the guidance page, ‘Check if you can claim back Statutory Sick Pay paid to employees due to coronavirus (COVID-19)’, were advertised, other changes were also made. In particular, it is highlighted that individuals quarantining upon return to the UK do not qualify for Statutory Sick Pay, unless they also qualify under any of the other pre-existing reasons (e.g. have symptoms, are self-isolating because someone they live with has symptoms, have been notified by NHS or public health bodies that they’ve come into contact with someone with coronavirus or are shielding as instructed by NHS or a GP)

     

    19th June

    The FCA “announced proposals which would provide continued support for users of certain consumer credit products, who are facing a financial impact because of the exceptional circumstances arising from coronavirus.”

     

    18th June

    “The VAT payment deferral period ends on 30 June 2020. This means you’ll need to: set-up cancelled direct debits in enough time for HMRC to take payment; submit VAT returns as normal, and on time; pay the VAT in full on payments due after 30 June; Any VAT payments you have deferred between 20 March and 30 June should be paid in full on or before 31 March 2021. You can make additional payments with subsequent returns.”

     

    15th June

    The Treasury Committee published a unanimously-agreed interim report as part of its inquiry into the Economic Impact of Coronavirus called Gaps in Support, urging the government to act to help “million-plus people who have lost livelihoods while being locked down and locked out of support” – the most relevant highlighted groups here are the newly self-employed, those self-employed with annual trading profits in excess of £50,000 and directors of limited companies who take a large part of their income in dividends. The chair of the committee said “If it is to be fair and completely fulfil its promise of doing whatever it takes, the Government should urgently enact our recommendations to help those who have fallen through the gaps.”

     

    12th June

    – Further information about the extension to the Self Employment Income Support Scheme was added.
    – Coronavirus Job Retention Scheme guidance pages were updated with information about how the scheme is changing: “From 1 July, employers can bring furloughed employees back to work for any amount of time and any work pattern, while still being able to claim the grant for the hours not worked. From this date, only employees that you have successfully claimed a previous grant for will be eligible for more grants under the scheme. From 1 August 2020, you will be asked to contribute towards the cost of your furloughed employees’ wages. Find out more information on how the Coronavirus Job Retention Scheme is changing.” – It was also specifically affirmed that when your employee is on furlough, they may “work for another employer (if contractually allowed)” – this particularly affects limited company directors who find themselves separate employment while furloughed from their company. Also, “From 1 August employers will be required to pay all employer NICs and pension contributions.”
    – Specific guidance was added to cover Holiday entitlement and pay during coronavirus (COVID-19)

     

    2nd June

    The FCA “confirmed the support firms should give to mortgage customers who are either coming to the end of a payment holiday or who are yet to request one. The FCA is also reminding customers that if they can afford to resume payments, they should.”

     

    29th May

    – A new guidance document was added to cover the Local Authority Discretionary Grants Fund, whereby “Small and micro businesses with fixed property costs that are not eligible for the Small Business Grant Fund or the Retail, Hospitality and Leisure Grant Fund may be eligible for the Discretionary Grants Scheme.” – though this document currently redirects you to your local council

    – During the daily briefing this evening, the Chancellor announced the extension of the Self-Employment Income Support Scheme for another three months, with those eligible able to claim a second “and final” grant, this time at 70% of average profits and capped at £6,570. It will be paid, as before, in a single instalment and is planned to be available in August. “An individual does not need to have claimed the first grant to receive the second grant: for example, they may only have been adversely affected by COVID-19 in this later phase.” See the associated press release, here

    – Also during the daily briefing, the Chancellor explained the tapering and planned end of the Coronavirus Job Retention Scheme, and an earlier delivery of the planned flexibility to bring furloughed employees back part-time, which will start from 1st July. Regarding tapering, the result will be that:

    “June and July: The government will pay 80% of wages up to a cap of £2,500 as well as employer National Insurance (ER NICS) and pension contributions. Employers are not required to pay anything.

    August: The government will pay 80% of wages up to a cap of £2,500. Employers will pay ER NICs and pension contributions – for the average claim, this represents 5% of the gross employment costs the employer would have incurred had the employee not been furloughed.

    September: The government will pay 70% of wages up to a cap of £2,187.50. Employers will pay ER NICs and pension contributions and 10% of wages to make up 80% total up to a cap of £2,500. For the average claim, this represents 14% of the gross employment costs the employer would have incurred had the employee not been furloughed.

    October: The government will pay 60% of wages up to a cap of £1,875. Employers will pay ER NICs and pension contributions and 20% of wages to make up 80% total up to a cap of £2,500. For the average claim, this represents 23% of the gross employment costs the employer would have incurred had the employee not been furloughed.”

    More details available in the associated press release, here

     

    28th May

    – Clarity brought to SSP reclaim guidance to highlight that “You can now claim for employees who are self-isolating because they’ve been notified by the NHS or public health bodies that they’ve come into contact with someone with coronavirus” complimenting the launch of ‘track and trace’

     

    26th May

    – As planned, the “Coronavirus sick pay scheme opens for applications” which “allows small and medium sized employers, with fewer than 250 members of staff, to apply to recover the costs of paying coronavirus-related Statutory Sick Pay for two weeks – worth nearly £200 per employee.” And “after making an application employers will receive the money within six working days.” – see press release, access the service here, service availability information can be found here

     

    22nd May

    FCA and the Treasury both announced an extension to the help for homeowners with their mortgages, whereby “Where consumers can afford to re-start mortgage payments, it is in their best interests to do so. But where they can’t, a range of further support will be available. People who are struggling and have not had a payment holiday, will continue to be able to apply until 31 October.” Note in particular that “the current ban on repossessions of homes will be continued to 31 October 2020” and that “Payment holidays and partial payment holidays offered under this guidance should not have a negative impact on credit files.”

     

    19th May

    – The SSP rebate scheme is set to launch from 26th May, according to this press release, and “a loss of, or change in, your normal sense of taste or smell (anosmia)” was added to the list of symptoms whereby display of any such symptoms require the sufferer and their household to self-isolate and thus become eligible for SSP (self-isolation guidance can be found here)

    – The link to “check the status of your payment” was reinstated on the page where you can claim through the Self Employment Income Support Scheme

     

    18th May

    – A Convertible Loan Agreement document was added to the Future Fund guidance, and it is noted that it will open for applications on 20th May

    – The maximum loan size available to large businesses was raised from £50m to £200m according to this press release, subject to restrictions on dividend payments, senior pay and share buy-backs during the loan period, “including a ban on dividend payments and cash bonuses, except where they were previously agreed” applying “beyond 12 months from today” to “ensure that the money is used to keep the company going through the crisis. The Bank will also publish a list of companies who have benefitted under CCFF on 4 June.”

     

    15th May

    – A guidance document was introduced for those who complete Self Assessments and would have a payment on account due in July, to help them “Choose how and when you can delay making your second payment on account for the 2019 to 2020 tax year” – in particular, stating that “You do not need to tell HMRC that you’re deferring your payment on account.” and “HMRC will not charge interest or penalties on any amount of the deferred payment on account, provided it’s paid on or before 31 January 2021”

    – The link to “check the status of your payment” has been removed from the page where you can claim through the Self Employment Income Support Scheme – either it was not the proper place, or the service has been removed (when I go to where the previous link led, I am now met with an error message: “For your security, this service has been reset. The details you have given have been deleted.”)

     

    14th May

    “FCA confirms measures to help insurance customers who may be suffering financial difficulties as a result of coronavirus” – requiring firms to reassess the risk profile of customers as “there may be scope to offer customers materially lower premiums”, consider if there are other more suitable products to switch customers to e.g. “a motor insurance customer might no longer need associated add on cover such as key cover or could be moved from fully comprehensive cover to third party fire and theft”, and also waive cancellation fees and other fee associated with adjusting policies. “These actions could result in a reduction in the monthly premium for customers paying by instalments or a partial refund of the premium for customers who have paid up front. Where amendments to the insurance cover do not help alleviate the temporary payment difficulties for customers paying their premium in instalments, then the FCA expects firms to grant customers a payment deferral unless it is obviously not in the customer’s interests to do so. The payment deferral should be granted for a period of between 1 and 3 months, though firms can go beyond 3 months should they wish to do so, and it is in the customer’s interests. Customers should be able to request a payment deferral at any point during the period up to 18 August 2020 while the window for requesting a payment deferral is open.” Alternatives are listed where payment deferral is not considered appropriate and there is a continued expectation to consider lowering interest rates. The measures would come into force by the end of May 2020. See the full press release here

    – Self Employment Income Support Scheme statistics released: on 13th May 441,000 claims were made totalling £1.3bn – see statistics here

    – A ‘How to make a claim’ video regarding the Self Employment Income Support Scheme was added here

    – The temporary suspension of ‘wrongful trading rules’ was extended to 30th June – see the updated press release here

    – Examples to help employers calculate 80% of their employees’ wages for the Coronavirus Job Retention Scheme were added here

     

    13th May

    – The Self Employment Income Support Scheme is now generally available for applications here, though the guidance document states you should “Make your claim from the date we gave you when you checked your eligibility.” The following statement has also been added: “You should not claim the grant if you’re a limited company”, though this is not well written – a limited company is a separate legal entity to an individual: Use of the word ‘you’re’ indicates the limited company itself may not claim, but a self-employed individual who happens to also be a person of significant control (e.g. sole director) of a limited company would not seem to be specifically excluded from claiming by this statement, if they are otherwise eligible. Note “If you submitted your returns between 26 March 2020 and 23 April 2020 check your eligibility again as the online service has been updated.” – according to the associated press release, which could be due to the many claims that the calculator has been giving false results – the guidance document notes that “If you still think you should be able to claim you can ask HMRC to review your eligibility”, which you can do here. People can claim “on a specified date between 13-18 May, based on their Unique Tax Reference number” which “can be checked on HMRC’s online checker” here, and “will be able to receive the government grant by 25 May, or within six days of a completed claim.”

    “Businesses with supply chains which rely on Trade Credit Insurance and who are experiencing difficulties maintaining cover due to Coronavirus will get support from the government, the Economic Secretary to the Treasury, John Glen has announced.” – see press release here

     

    12th May

    – The chancellor revealed that the furlough scheme will be extended until the end of October. “From the start of August, furloughed workers will be able to return to work part-time with employers being asked to pay a percentage towards the salaries of their furloughed staff. The employer payments will substitute the contribution the government is currently making, ensuring that staff continue to receive 80% of their salary, up to £2,500 a month. […] The scheme will continue in its current form until the end of July and the changes to allow more flexibility will come in from the start of August. More specific details and information around its implementation will be made available by the end of this month.” – The chair of the Treasury Committee has also commented, welcoming the measure, but also stating: “The Chancellor also said that there will be no changes to the scheme until July. This will be worrying for those who continue to fall through the gaps of the Government’s support measures such as the lack of furlough support to help cover dividend income generated through self-employment.”

     

    11th May

    – New collection of guidance documents have been launched: Working safely during coronavirus (COVID-19)

    – Revised version of Coronavirus Job Retention Scheme: step by step guide for employers was published “that is clearer and includes recent additions to the process”

     

    7th May

    – The Coronavirus Job Retention Scheme service now allows you to save a claim and finish it later

    – More details emerged re the Bounce Back Loan, with clarity added to the guidance document to highlight that small and medium sized businesses may “borrow between £2,000 and up to 25% of their turnover. The maximum loan available is £50,000.” also “there won’t be any fees or interest to pay for the first 12 months. After 12 months the interest rate will be 2.5% a year.” suggesting that interest will not accrue immediately. Also, “The length of the loan is 6 years, but you can repay early without paying a fee. No repayments will be due during the first 12 months.” However, I am not reassured by the statement: “The lender will decide whether to offer you a loan or another type of finance” as it makes me wonder whether lenders may choose to direct you to products that are more profitable to themselves, rather than this scheme, after you apply. Though it is reassuring to note that “If one lender turns you down, you can apply to other lenders in the scheme”

     

    6th May

    “More than 69,000 Bounce Back Loans worth over £2 billion have been approved during the first 24 hours of the scheme” according to this press release from HM Treasury

     

    5th May

    – A specific date for the Self-Employment Income Support Scheme online service to be online was added: 13th May. However, “If you’re eligible, we will tell you the date you can make your claim from.” – presumably a way of spreading the load on this system, and I expect that to be enforced. Once approved, “you’ll receive your payment within 6 working days.”

     

    4th May

    – A tool was added to allow you to check if you’re eligible to claim for Self Employed Income Support Scheme: https://www.tax.service.gov.uk/self-employment-support – however, the benefit of this tool may be limited, given that HMRC will work out if you’re eligible and write to you if you are, anyway)

    – The bounce back loan scheme online application form opened, here: https://www.british-business-bank.co.uk/ourpartners/coronavirus-business-interruption-loan-schemes/bounce-back-loans/ – however no singleshort and simple form” appears to be available at this time, as all potential applicants are being directed to choose a lender and find out how to apply through them individually. However, a Treasury press release claims that (presumably for each lender) “small business owners can apply to accredited lenders by filling out a simple online form, with only seven questions.” – More importantly, however: “The government has also agreed with lenders that an affordable flat rate of 2.5% interest will be charged on these loans” (Note: the government covers the cost of any fees and interest for the first 12 months) “And any business that has already taken out a Coronavirus Business Interruption Loan of £50,000 or less can apply to have these switched over to this generous new scheme.”

    – The eligibility criteria that a business “was not an ‘undertaking in difficulty’ on 31 December 2019” has now been removed from the bounce back loan scheme, meaning that such businesses may apply

    – Applicable to those claiming tax credits, an HMRC press release today states that “Tax credits customers will continue to receive payments even if working fewer hours due to COVID-19” also stating “These customers do not need to contact HMRC about this change. We will treat customers as working their normal hours until the Job Retention Scheme and Self-Employment Income Support Scheme close, even if they are not using either scheme.”

     

    2nd May

    – The Self-Employed Income Support Scheme guidance document added the following explicit statement: “If you receive the grant you can continue to work, start a new trade or take on other employment including voluntary work, or duties as an armed forces reservist.” (It continues to state “If you have other employment as a director or employee paid through PAYE your employer may be able to get support using the Coronavirus Job Retention Scheme”) – examples of ways you may have been adversely affected by coronavirus were added, highlighting that this is not restricted to being directly affected only by sickness or the Government instructions for the public to stay at home (e.g. it includes interrupted supply chains, fewer customers/clients and staff unable to come to work.) – it has also been highlighted that “Your tax agent or adviser cannot make the claim for you. You must make the claim yourself. If you use an agent you should contact them if you need any help or support.”

    – HMRC introduced a digital assistant to aid in finding information about Coronavirus support schemes. It can be found here: https://www.tax.service.gov.uk/ask-hmrc/virtual-assistant/support-for-coronavirus

    – A relatively unpromoted press release was made by several government departments, speaking of a “Top-up to local business grant funds scheme” designed “to accommodate certain small businesses previously outside the scope of the business grant funds scheme.” The release states: “We are asking local authorities to prioritise businesses in shared spaces, regular market traders, small charity properties that would meet the criteria for Small Business Rates Relief, and bed and breakfasts that pay council tax rather than business rates. But local authorities may choose to make payments to other businesses based on local economic need. The allocation of funding will be at the discretion of local authorities. Businesses must be small, under 50 employees, and they must also be able to demonstrate that they have seen a significant drop of income due to Coronavirus restriction measures. There will be three levels of grant payments. The maximum will be £25,000. There will also be grants of £10,000. local authorities will have discretion to make payments of any amount under £10,000. It will be for councils to adapt this approach to local circumstances.” With no further guidance given on how small businesses can claim from this scheme, the only point of contact would be your local authority – though be aware that they may not yet know any of the details about this scheme as “Further guidance for local authorities will be set out shortly.”

     

    1st May

    – Comments were added to the Coronavirus Job Retention Scheme guidance documents to cover where more complex scenarios apply, involving maternity pay, adoption pay, paternity pay, shared parental pay or parental bereavement pay. Also, Company directors with an annual pay period, whose only salary payment to themselves in 2019-20, notified to HMRC through payroll software, was (or would have been) after 19th March 2020, are explicitly held to the same rules as other kinds of employee and are thus not eligible for this scheme. Larger employers may be reassured to see the explicit statement that “Coronavirus Job Retention Scheme grants are not classed as state aid.”

    “FCA seeks legal clarity on business interruption insurance alongside package of measures to help consumers and small businesses […] The Financial Conduct Authority (FCA) has today announced it intends to seek legal clarity on business interruption (BI) insurance to resolve doubt for businesses who are facing uncertainty on their claims.” – see the full press release here – Mel Stride, chair of the Treasury Committee, has commented on this, calling the steps taken by FCA “extremely welcome” and stating that “The Committee will be pressing for rapid progress. Those who should be paid, should be paid as soon as possible.”

    – More examples were added to the guidance document: How HMRC works out trading profits and non-trading income for the Self-Employment Income Support Scheme to handle some more complex scenarios

     

    28th April

    – Webinar about Coronavirus (COVID-19) Statutory Sick Pay (SSP) rebate scheme has been added: https://www.gov.uk/guidance/help-and-support-if-your-business-is-affected-by-coronavirus-covid-19

     

    27th April

    – The VAT payments eligible for deferral have been outlined in greater detail: You can only defer quarterly and monthly VAT returns’ payments for the periods ending in February, March and April; payments on account due between 20 March 2020 and 30 June 2020; annual accounting advance payments due between 20 March and 30 June 2020. As before, “the deferral does not cover payments for VAT MOSS or import VAT”. It is also highlighted that HMRC will “continue to process VAT reclaims and refunds as normal […and…] not be offset against any deferred VAT”. If you wish to defer your VAT payment, you are still advised to cancel your Direct Debit, and you that you must pay the VAT due on or before 31 March 2021.

    – The Coronavirus Job Retention Scheme calculator can now be used to work out what you can claim for employees who are paid variable amounts each pay period: https://www.tax.service.gov.uk/job-retention-scheme-calculator/

    – In a statement to the Houses of Parliament, the chancellor said “over 20,000 Coronavirus Business Interruption Loans have now been approved” (which to my mind seems a ridiculously small number compared to the 5.82 million small businesses in the UK) and that “HMRC are also on track to deliver the Self-employed Income Support Scheme, as promised, in early June, and we will publish detailed guidance this week.” He also revealed the new Bounce Back Loans (see below)https://www.gov.uk/government/speeches/chancellors-statement-to-parliament

    – The government announced a new ‘Bounce Back Loan’ scheme: “whereby businesses will be able to borrow between £2,000 and £50,000 and access the cash within days […] interest free for the first 12 months, and businesses can apply online through a short and simple form” This is a “new fast-track finance scheme providing loans with a 100% government-backed guarantee for lenders […]  designed to ensure that small firms who need vital cash injections to keep operating can get finance in a matter of days […] No repayments will be due during the first 12 months.” Also, “the government will work with lenders […] and agree a low standardised level of interest for the remaining period of the loan” The scheme will launch for applications on Monday 4 May. “There will be no forward-looking tests of business viability; no complex eligibility criteria; just a simple, quick, standard form for businesses to fill in.” and “For most firms, loans should arrive within 24 hours of approval.” Once available, you may apply here (some eligibility criteria are already stated): https://www.gov.uk/guidance/apply-for-a-coronavirus-bounce-back-loan

     

    24th April

    – “The FCA will be introducing the package of measures outlined last week to support consumer credit customers facing payment difficulties due to coronavirus (Covid-19).” – https://www.fca.org.uk/news/press-releases/fca-confirms-support-motor-finance-and-high-cost-credit-customers – now in force as of Monday 27th April: “a 3 month payment freeze for motor finance, buy-now pay-later (BNPL), rent-to-own (RTO) and pawnbroking agreements. For high-cost short term credit (including payday loans) payments will be frozen for one month with no additional interest to be charged.”

    – The British Business Bank has amended the eligibility criteria listed on its website for the Coronavirus Business Interruption Loan Scheme, namely highlighting the ineligibility of small businesses who “have been classed as a ‘ business in difficulty ’ on 31 December 2019, if applying to borrow £30,000 or more.”

     

    23rd April

    – A section was added to the Coronavirus Job Retention Scheme guidance documents making it clear that if an employee was made redundant or stopped working after 28th February (but were on their payroll at that time), or after 19th March (but were on their payroll at that time), the employer can agree to re-employ them and place them on furlough.

    – Collective agreements between trade unions and employers are now considered acceptable agreements that employees may be furloughed under the Coronavirus Job Retention Scheme

    – The Treasury Committee requested cooperation from lenders for daily updates on the coronavirus business loans: https://committees.parliament.uk/committee/158/treasury-committee/news/146089/committee-requests-cooperation-from-cbils-lenders-on-providing-daily-data-update/

    – Webinar about Coronavirus (COVID-19) – Self-employment Income Support Scheme (SEISS) and a YouTube video with a step-by-step guide on how to make a claim through the Coronavirus Retention Scheme have been added.: https://www.gov.uk/guidance/help-and-support-if-your-business-is-affected-by-coronavirus-covid-19

     

    21st April

    – The Chancellor responded to the Treasure Committee on help for those not eligible for Government’s support measures: https://committees.parliament.uk/committee/158/treasury-committee/news/146064/chancellor-responds-to-treasury-committee-on-help-for-those-not-eligible-for-governments-support-measures/

    – The Treasury Committee requested daily updates on the coronavirus business loans: https://committees.parliament.uk/committee/158/treasury-committee/news/145972/treasury-committee-requests-daily-updates-on-coronavirus-business-loans-to-drive-further-vital-lending/

    – Webinar about Coronavirus (COVID-19) Job Retention Scheme – how to make a claim has been added: https://www.gov.uk/guidance/help-and-support-if-your-business-is-affected-by-coronavirus-covid-19

    – The Chancellor answered the Treasury Committee’s requests regarding those ineligible for the existing support measures – but little flexibility was displayed. You can find the response here: https://committees.parliament.uk/committee/158/treasury-committee/news/146064/chancellor-responds-to-treasury-committee-on-help-for-those-not-eligible-for-governments-support-measures/

     

    20th April

    – The Coronavirus Job Retention Scheme online portal is now open: https://www.gov.uk/guidance/claim-for-wages-through-the-coronavirus-job-retention-scheme – “Once you’ve claimed, you’ll get a claim reference number. HMRC will then check that your claim is correct and pay the claim amount by Bacs into your bank account within 6 working days.”

    – A service availability link was added that you can use to check it’s all operational: https://www.gov.uk/government/publications/coronavirus-job-retention-scheme-service-availability-and-issues/coronavirus-job-retention-scheme-service-availability-and-issues

    – A calculator was added that “can currently be used to work out what you can claim for most employees who are paid the same amount each pay period” – https://www.gov.uk/guidance/work-out-80-of-your-employees-wages-to-claim-through-the-coronavirus-job-retention-scheme

    – The Future Fund was announced, whereby the government “will provide [convertible] government loans to UK-based companies ranging from £125,000 to £5 million, subject to at least equal match funding from private investors” provided your business “has previously raised at least £250,000 in equity investment from third-party investors in the last 5 years” – to launch in May. Details here: https://www.gov.uk/guidance/future-fund

    – A ‘Business Support Finder’ tool was launched, which can be found here: https://www.gov.uk/business-coronavirus-support-finder

     

    17th April

    – The Coronavirus Job Retention Scheme was extended by one month (to the end of June) to reflect continuing social distancing measures – see the press release, here: https://www.gov.uk/government/news/chancellor-extends-furlough-scheme-to-end-of-june

    – A step-by-step Coronavirus Job Retention Scheme guide for employers was published on 17th April, available here: https://www.gov.uk/government/publications/coronavirus-job-retention-scheme-step-by-step-guide-for-employers

    – Since SSP was extended to cover all those who are shielding, the guidance was updated to highlight that employers can also reclaim for those employees claiming SSP who “are shielding in line with public health guidance” – but the reclaimable amount is still limited to up to 2 weeks of this 12-week+ self-isolation period, throughout which they will be entitled to SSP

    – A guidance document was published, entitled “Work out 80% of your employees’ wages to claim through the Coronavirus Job Retention Scheme”, here: https://www.gov.uk/guidance/work-out-80-of-your-employees-wages-to-claim-through-the-coronavirus-job-retention-scheme

    “The FCA has today announced another proposed package of measures to directly support consumers facing payment difficulties due to coronavirus (Covid-19). The range of targeted temporary measures cover motor finance and high cost credit agreements, which include: high-cost short-term credit (including payday loans), buy-now pay-later (BNPL), rent-to-own (RTO) and pawnbroking.”https://www.fca.org.uk/news/press-releases/fca-proposes-help-motor-finance-high-cost-credit-customers-coronavirus

     

    16th April

    We missed it at the time, but legislation came into force extending SSP to cover those who are shielding – http://www.legislation.gov.uk/uksi/2020/427/pdfs/uksi_20200427_en.pdf

     

    15th April

    – The Treasury announced an extension of the eligibility cut off date for the Coronavirus Job Retention Scheme. The date that an employee must have been on the payroll (on or before) to be eligible was extended from 28th February to 19th March – see: https://www.gov.uk/government/news/furlough-scheme-cut-off-date-extended-to-19-march

    – The British Business Bank page on the Coronovirus Business Interruption Loan quietly added the following statement: “Lenders will need further information to confirm eligibility. All lending decisions remain fully delegated to the 40+ accredited lenders” – presumably small businesses are unsure why their loan requests are being turned down given they believe they satisfy the requirements otherwise listed there: “Your business must: Be UK-based in its business activity; Have an annual turnover of no more than £45 million; Have a borrowing proposal which the lender would consider viable, were it not for the current pandemic; Self-certify that it has been adversely impacted by the coronavirus (COVID-19).” – Are lenders turning down otherwise healthy businesses in need of the loan according to their own additional proprietary criteria?

     

    14th April

    – HMRC introduced a guidance document illustrating how they calculate total income and trading profits for the Self-Employment Income Support Scheme: https://www.gov.uk/guidance/how-hmrc-works-out-total-income-and-trading-profits-for-the-self-employment-income-support-scheme

    – The Chancellor revealed, during the daily briefing, that the ‘online portal’ for the Coronavirus Job Retention Scheme is currently in testing, and anticipated to become available on or around 20th April, after which it will be “several days to get the cash”

     

    12th April

    – The Business Support FAQs page specifically on Coronavirus was removed, now pointing instead to the recently compiled collection: https://www.gov.uk/government/collections/financial-support-for-businesses-during-coronavirus-covid-19

     

    10th April

    – Coronavirus Job Retention Scheme documentation updated to confirm that those working through limited companies, in-scope of IR35 legislation and with a public-sector engagement (‘off payroll’) may be furloughed under this scheme for that engagement, and also that foreign nationals are eligible – details here

    – Clarity brought re SSP eligibility while ‘furloughed’ under the Coronavirus Job Retention Scheme: You may (but do not have to) use SSP for workers who are furloughed and then become sick (though sick workers must be paid at least SSP) – since both are reclaimable, the higher pay rate will probably be the best to use for all involved

     

    9th April

    – “FCA confirms temporary financial relief for customers impacted by coronavirus” – https://www.fca.org.uk/news/press-releases/fca-confirms-temporary-financial-relief-customers-impacted-coronavirus

     

    8th April

    – The previously linked and heavily referenced ‘COVID-19 Support For Businesses’ document was removed, replaced with a ‘collection’ of guidance documents representing it’s former constituent parts: https://www.gov.uk/government/collections/financial-support-for-businesses-during-coronavirus-covid-19

    This document was updated to reflect that the Chancellor has explicitly stated on 3rd April, via a video Tweet, that neither eligibility nor the calculation of the Self-Employment Income Support Scheme will extend to 2019-20 self assessments – see this via the moneysavingexpert blog, here: https://blog.moneysavingexpert.com/2020/04/nine-things-the-chancellor-could-tweak–to-help-people-through-t/#provisionaltax

    The support for charities announcement was added: https://www.gov.uk/government/news/chancellor-sets-out-extra-750-million-coronavirus-funding-for-frontline-charities

    The Treasury Select Committee inquiry request for the Chancellor to address the gaps was added: https://committees.parliament.uk/committee/158/treasury-committee/news/145875/treasury-committee-urgent-action-needed-for-those-not-eligible-for-treasurys-support-measures/

     

    4th April

    Business FAQs updated with sections on: ‘I have questions about employment and employing my staff – where can I go?’, ‘ What proof do my employees need to provide to take sick leave?’, ‘ I employ people on zero hours contracts / gig economy workers. Can they access support?’, ‘ How does this impact my apprentices or apprenticeships?’, ‘ I cannot afford to pay my mortgage, what do I do?’, ‘ Can I get any help to reduce my business’ energy bills?’, ‘ What can I do as a small business experiencing late payments from bigger businesses?’ and ‘ Can I help with the supply of ventilators?’

    – Coronavirus Job Retention Scheme guidance updated, including for specific scenarios including apprentices, limited company directors, agency workers and those working through an umbrella company. The guidance also clarified: the applicable ‘earnings’ upon which the 80% calculation will be based; that usual PAYE deductions (such as income tax, national insurance and student loan contributions) are still due; that a worker may not do work for the employer ‘or a company linked or associated to your employer’ while furloughed, presumably to prevent some gaming of the system; that ’employers must confirm in writing to their employee confirming that they have been furloughed’ and that a record ‘must be kept for five years.’

     

    3rd April

    – The Coronavirus Business Interruption Loan scheme rules were significantly changed, after a mere 983 loan approvals out of 130,000 applications over this previous week. The (unnecessarily anti-bank spun) official press release can be found here: https://www.gov.uk/government/news/chancellor-strengthens-support-on-offer-for-business-as-first-government-backed-loans-reach-firms-in-need

    – The Coronavirus Large Business Interruption Loan Scheme page was inexplicably removed, and then added again here: https://www.businesssupport.gov.uk/coronavirus-large-business-interruption-loan-scheme/

    – New guidance from HMRC re employers reclaiming Coronavirus-related SSP costs (but no new information and no online portal for claiming as yet) https://www.gov.uk/guidance/claim-back-statutory-sick-pay-paid-to-employees-due-to-coronavirus-covid-19

    – Coronavirus Large Business Interruption Loan scheme info added to the main ‘Covid-19: support for business’ document

    – Advice for those wanting to receive the grants available to those in the retail, hospitality or leisure industries paying business rates, or those paying little or no business rates due to Small Business Rate Relief or Rural Rate Relief, has been updated to indicate that though the local authority will still write to you, some are still operating an applications procedure

    – Business FAQs added a specific FAQ page on the Self-Employment Income Support scheme, here: https://www.businesssupport.gov.uk/self-employment-income-support-scheme-faqs/

    – VAT deferrals confirmed not to include payments for import VAT

     

    2nd April

    – The Financial Conduct Authority has proposed temporary financial relief for customers impacted by coronavirus, expected to become effective from 9th April. Press release, here: https://www.fca.org.uk/news/press-releases/fca-proposes-temporary-financial-relief-customers-impacted-coronavirus

    – The central ‘COVID-19: support for businesses’ document has removed it’s partial outlining of the scheme rules for the Coronavirus Business Interruption Loan scheme, instead now redirecting the reader to https://www.british-business-bank.co.uk/ourpartners/coronavirus-business-interruption-loan-scheme-cbils-2/for-businesses-and-advisors/

    – The Coronavirus Large Business Interruption Loan Scheme was added, details available here: https://www.businesssupport.gov.uk/coronavirus-large-business-interruption-loan-scheme/

     

    1st April

    – SSP guidance updated to include Coronavirus: https://www.gov.uk/guidance/statutory-sick-pay-manually-calculate-your-employees-payments

    (Note for payroll experts: I previously suggested that Periods of Incapacity for Work (PIW) may in the end be worked out as un-linked in the case of either contributing periods being due to Coronavirus, but the absence of this change in the above document now suggests this will not be the case. Regardless, it should have no effect on the pay available to employees, as SSP is payable from day 1 of any Coronavirus-related leave (regardless of PIW calculations) anyway and Coronavirus-related leave is always more than 3 days, so following unrelated sickness would also never have any ‘waiting days’ to ‘carry over’)

     

    31st March

    – We found and referenced the press release from 28th March detailing how ‘Wrongful trading’ rules are intended to be suspended for limited company directors to allow them to trade through this with confidence they will not become personally liable for their company’s debts

     

    28th-30th March

    – Business Support FAQs were updated to include a reminder that the planned ‘off-payroll’ (IR35) changes are not going ahead for the tax year 2020-21

    – Minor changes to wording of HMRC guidance documents that improve clarity

    – Ben Kerry (Head of Labour Markets, HMT) spoke during a webinar held by the CBI, clarifying the applicability of the Coronavirus Job Retention Scheme to limited company owner/directors – see timestamp 27:20 of the following recording: https://www.cbi.org.uk/articles/daily-coronavirus-webinar-job-retention-scheme-27-03-2020/

    – Business Support FAQs overhauled the section ‘I employ people on zero hours contracts / gig economy workers. Can they access support?’ – previously this section directed the reader only to SSP and ESA – it now points toward the Coronavirus Job Retention scheme

    – Business Support FAQs overhauled the section ‘What if I am self-employed?’ – previously this section directed the reader to Universal Credit, Rent deferral, Mortgage deferral, Tax Bill deferral, Business VAT deferral, IR35 deferral and (in a previous instance) Energy Bill deferral – it now points toward the Self-employed Income Support scheme

    – The ‘COVID-19: support for businessses’ document was amended to better explain the Coronavirus Job Retention scheme, brought clarity that it is ‘Self-Assessment payments on account’ that may be deferred, and no ‘Income Tax’ more generally, specifying 31st January 2021 as last payment date beyond which those payments would be once again regarded as late. Also, the Time To Pay service telephone number was amended from 0800 0159 559 to 0800 024 1222 (the old number was thus removed from this page)

     

    27th March

    – New HMRC guidance documents launched, referenced above

    – A new scam is noted regarding a ‘£250 fine’

    – The Self-employed Income Support scheme seems to be inapplicable to limited company owner/directors, due to the concluding paragraph of the guidance document

    – Business Support FAQs were updated to include a link to a resource to tell the government if you think your business can help: https://www.gov.uk/coronavirus-support-from-business

     

    26th March

    – The general banner explaining the need to ‘stay at home’ was reworded, to little effect

    – The main links at the top of the businesssupport.gov.uk website were updated to become more specifically focused on coronavirus – in particular we have started to watch the general page: https://www.businesssupport.gov.uk/coronavirus-business-support/ which appears to be a hub for detail on the available support

    – The businesssupport.gov.uk FAQ page removed a list item suggesting that Energy Bill deferral would be available to the Self Employed. If it was not there in error in the first place, this might seem to indicate that the energy sector is unwilling to provide the support that the government had hoped it would be able to offer – since we had heard nothing about such support through any other channels, it may be simply have been an error.

    – A resource at https://www.businesssupport.gov.uk/self-employment-income-support-scheme/ was added to outline the new support available for the self-employed

    – A more useful HMRC guidance document for Coronavirus Self Employment Income Support scheme was introduced, and can be found here: https://www.gov.uk/guidance/claim-a-grant-through-the-coronavirus-covid-19-self-employment-income-support-scheme (links to the businesssupport.gov.uk website, mentioned above, have now been replaced with this more authoritative reference throughout this page)

     

    25th March

    – Commercial insurance section expanded with an event coverage section added, making it more clear that you probably are NOT covered, as ‘pandemic’ or ‘notifiable disease’ cover is not common.

    – A link stating “Check the business support website for answers to frequently asked questions” was added, but the FAQ offers little new information as yet.

    – The specific statement: “Customers who normally pay by direct debit should cancel their direct debit with their bank if they are unable to pay. Please do so in sufficient time so that HMRC do not attempt to automatically collect on receipt of your VAT return.” has been removed. Since the advice has not been formally retracted, it is just no longer being given, my personal recommendation would be to continue to cancel the direct debit if you need to. It has been amended to clarify that no late penalties or interest will be applied “if you defer payment until January 2021”, presumably to ensure it is not misinterpreted as inferring you would never attract penalties or late interest if you were to withhold payment indefinitely.

    – A banner across the top of the site giving a general ‘stay at home’ message was added

     

    24th March

    – Specific links to the guidance for local authorities were added for the rates holidays schemes, presumably because many were unaware of the guidance and were referring to this same document themselves

    – Explicit guidance has been added to state that if you are VAT registered and want to defer your next VAT payment for the bill that would have been due between 20th March and 30th June 2020, you should cancel your direct debit – no late penalties or interest will be payable.

    – Sections added to inform us that commercial renters are being protected from eviction and that BID ballots are being delayed

     

    23rd March

    – Minor typos and clarity over the £15,000 vs £15,001 limit on rateable value for grants regarding property

    – The section entitled “Cash grants for retail, hospitality and leisure businesses” has had it made clear that these rates are related to property. This is a welcome change as businesses without property were unsure if they could benefit from these grants – they can’t.

    – The section “Support for nursery businesses that pay business rates” was added

    – The section entitled “Support for businesses through the Coronavirus Business Interruption Loan Scheme” was updated to make it clear that the scheme is now available through 40 commercial lenders, “including all the major banks.” with a list added, available here: https://www.british-business-bank.co.uk/ourpartners/coronavirus-business-interruption-loan-scheme-cbils/accredited-lenders/

    – Also, the following was added: “If you have an existing loan with monthly repayments you may want to ask for a repayment holiday to help with cash flow”

    – Under the section “Support for larger firms through the COVID-19 Corporate Financing Facility” a note was added that, rather than all UK businesses being eligible, there was a backtrack and now “All non-financial companies that meet the criteria set out on the Bank of England’s website are eligible.” – presumably leaving some large financial institutions out in the cold.

    – Also, specific links were added for businesses based in Scotland, Wales and Northern Ireland, as “some elements of business support are devolved”

     

     

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