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Temporary Covid-19 Wage Subsidy Scheme

Phase 1 - March – 20th April 2020     What is the Scheme?  
  • The scheme will operate to refund employers up to 70% of the net wage paid to employee subject to the thresholds detailed below.
  • Refunds under this Scheme will be issued to employers with 2 working days.
  • It replaces the previous €203 refund scheme and any employer who opted to operate this scheme will be contacted by Revenue to transfer to this new scheme.
  • Employers are encouraged, but not obliged, to top-up the subsidy to bring the net wages of employees as close to 100% as possible.
  • The Scheme can be applied even if an employees working hours have been reduced.
  • The Scheme will operate in 2 phases:
Phase 1 – March to 20th April 2020 (this document only deals with Phase 1) Phase 2 – 20th April 2020 onwards (awaiting further guidance from Revenue)   Who Qualifies for the Scheme?  
  • The Scheme is available to employers who are:
experiencing significant negative economic disruption due to Covid-19 able to demonstrate a minimum of a 25% decline in turnover unable to pay normal wages and normal outgoings fully, and retain their employees on the payroll. The Scheme is only available to employees who were on the employer’s payroll as at 29th February 2020 and for whom a payroll submission has already been made to Revenue in the period from 1st February to 15th March 2020. The employer is not to pay in excess of an employee’s usual net wages. Employers who avail of the Scheme will be published on Revenue’s website.   How will the Scheme Operate?   Phase 1 - For March and up to 20th April 2020 (Transitional Period)  
  • During this period the Scheme will refund employers a maximum of €410 regardless of the employee’s income.
  • However for administration purposes the employer is being asked to return the following information on the payroll:
Set PRSI Class J9 Enter a non-taxable amount equal to 70% of the employee’s Average Net Weekly Pay to: maximum of €410 per week where the average net weekly pay is less than or equal to €586or maximum of €350 per week where the average net weekly pay is greater than €586 and less than or equal to €960.
  • The Scheme does not currently allow for any refund where the employees average net weekly pay is greater than €960 per week.
  • No IT, USC or PRSI is to be levied on the subsidy payment through payroll. The subsidy will be liable to IT and USC on review at the end of the year. Revenue have yet to announce how this will operate.
  • Employer’s PRSI at a rate of 0.5% (down from 11.5%) applies to any top-up amounts.
  • IT and USC should be applied on any top-up amounts.
  • It is likely that the Scheme will trigger tax refunds for employees and employers can pay over the tax refunds to employees. Revenue will reimburse the tax refunds to employers.
  Phase 1 Examples                                                                                               (a)   Average Net Weekly Wages €210   Anna’s average net weekly wages is €210. In Phase 1 the refund will operates as follows:   On the payroll submission the Covid-19 refund amount will be declared as €147 (i.e. €210 @ 70%). Revenue will refund the employer €410 regardless.   The over-refunded amount €263 (i.e. €410 - €147) will be due back to Revenue. Though we are awaiting guidance on how that will operate in practice.   (b)   Average Net Weekly Wages €550   Tom’s average weekly wages is €550. In Phase 1 the refund for Tom’s employer will operate as follows:   On the payroll submission the Covid-19 refund amount will be declared as €385 (i.e. €550 @ 70%). Revenue will refund the employer €410 regardless.   The over-refunded amount €25 (i.e. €410 - €385) will be due back to Revenue.       (c)    Average Net Weekly Wages €586   Jack’s net weekly wages is €586. The refund scheme will operate as follows:   On the payroll submission the Covid-19 refund amount will be declared as €410 (i.e. €586 @ 70%) and Revenue will refund the employer €410 regardless.   There will be no ‘over-refunded’ element in this case.   (d)   Average Net Weekly Wages €675   Jane’s average net weekly wages is €675 (as this is above the €586 threshold above, Jane’s maximum subsidy under the Scheme will be capped at €350). The refund will operate as follows:   On the payroll submission the Covid-19 refund amount will be declared as €350 (i.e. the maximum threshold for this wage amount). Revenue will refund the employer €410 regardless.   The over-refunded amount €60 (i.e. €410 - €350) will be due back to Revenue.   (e)    Average Net Weekly Wages €1,110 Mark’s net weekly wages is €1,100. He breaches the €960 net weekly wage maximum and therefore is not entitled to avail of the scheme.   Phase 2 – 20th April 2020 Onwards   We are awaiting further guidance from Revenue in respect of this phase.   Kind Regards,   Vivian E. Nathan Managing Partner
March 27, 2020

Roberts Nathan – Business Continuity Update

The Irish Government has recently introduced unprecedented measures effective until March 29th at the earliest in order to protect the safety of everyone amid the current COVID-19 outbreak. As part of this the government has recommended social distancing and working from home where possible for the workforce.   As a service-focused firm, Roberts Nathan takes this advice very seriously and we have implemented our business continuity plans to ensure that we can continue to properly service our clients.   Service continuity Our offices remain open and we have the systems, technology and effective work practices to enable our staff to work remotely and continue to deliver a high-quality service for our clients. We have a core management team working from our offices and a Partner will be available at all times. As a consequence of this we will have Partners and staff working from the office on a rotational basis and remotely where appropriate.  This position may change and we will advise if it does.   Contact   We will continue to operate our main office lines and all contact numbers remain the same. You can call or email your relevant Partner at any time with any queries. In terms of meetings we will not be conducting any face to face meetings for the time being. We can facilitate Skype, video and tele-conferences where appropriate.   Business supports   The Government have announced a number of measures to support businesses and individuals and we will issue a separate email on this in due course. If we can help with the completion of any applications or any other queries you might have at this time please let us know. You will note that at this point most of what has been issued is only initial guidance but we will endeavour to keep you as fully informed as we can as soon as further information has been released.   You are not on your own - We are here to support and help you and your business at this time.   Take care and stay safe.   Kind Regards,   Vivian E. Nathan Managing Partner   Roberts Nathan Business Advisors, Audit & Tax  
March 19, 2020

CRO set key dates for the Register of Beneficial Owners

A statutory instrument establishing the much anticipated Central Registrar of Beneficial Ownership of Companies (RBO) was signed into law by the Minister for Finance, Paschal Donohoe on the 22nd March 2019. Timelines are now set and companies can expect to be contacted by the office of the RBO with regard to their filing obligations over the coming weeks. When will the RBO accept online filings? In accordance with the SI, the RBO will begin to accept on-line filings from 22nd June 2019, after which there will be five months for companies and Industrial and Provident Societies to file their RBO data without being in breach of their statutory duty to file. The office of the Registrar of Beneficial Ownership (RBO) will contact each company and Industrial and Provident Society about their filing obligations in the coming weeks. The RBO website will be launched on 29th April which will provide further information. Key Dates
  • 29th April 2019 – The RBO will launch an official website to provide further guidance.
  • 22nd June 2019 - The RBO will start accepting online submissions via live portal.
  • 22nd November 2019 – This will be the last date for companies formed prior to June 2019 to submit their details.
Companies incorporated after 22nd November 2019 will have five months to submit their details without being in default. If you would like assistance in submitting your details to the RBO, please don’t hesitate to get in touch and we’ll be glad to provide you with further guidance.   
April 10, 2019


In 2011 the introduction of the Multi-Unit Development Act (MUD Act) brought with it much needed regulation and guidance for the ownership and establishment of residential property management companies in relation to multi-unit developments in Ireland.  A multi-unit development is a development in which there are at least 5 residential units and those units share facilities, amenities and services. The MUD Act sets out a number of rules and regulations which residential property management companies must adhere to, as part of their responsibility for the common areas of a development. One specific requirement of the MUD Act is that an Annual General Meeting (AGM) must be held at least once in each year, during which the directors must present to the members an Annual Report of the company’s activities.  

Annual Reports for Residential Property Management Companies

 The Annual Report presented to the members of a residential property management company will cover a specific period, which is generally the preceding year's Financial Statements.  For example, a residential property management company with a financial year end of 31st December 2013 will prepare and present the Annual Report, providing details of these Financial Statements, at the AGM held during 2014. Details which are required to be included in the Annual Report are as follows:
  • A statement of income and expenditure incurred. (This will generally be taken from the Financial Statements of the company).
  • A statement of assets and liabilities of the company.  (This is to include details of amounts due to the company, amounts owed by the company and any bank balances held).
  • Details in relation to the sinking fund (which we will cover below), to include the following:

1.  The amounts currently held in the sinking fund,

2.  The amount of the annual contribution to the sinking fund for each member, along with details of the basis of how such     contribution was calculated.

  • Details of the annual service charge for the period covered by the annual report i.e. the preceding year’s charge, along with details of how the service charge was calculated. Such calculations will generally be in the format of a budget of costs borne by the management company, with the total costs apportioned between the number of units within the complex.
  • Details of the annual service charge for the current period, again providing details of how the service charge was calculated.
  • Details of any planned expenditure on non-routine items such as refurbishment or improvements which is to be conducted in the current period.
  • Details of the insurance cover taken out by the management company to include:-

1.  The insured value of the complex,

2.  The amount of the premium paid,

3.  The name of the insurance provider

4.  A summary of the principal risks covered by the insurance policy.

  • Details of the fire safety equipment installed in the development, along with details of the current maintenance agreements in place for such safety equipment.
  • Details of any contracts entered into between the management company and a director or directors of the company. For example, if one of the directors of the management company provides fire safety maintenance to the management company the details of this contract would need to be disclosed in the annual report, along with details of amounts paid for such services provided.
  As with other limited companies, residential property management companies are required to provide their members with 21 days notice of an AGM.    While a copy of the Annual Report is not required to be issued to the members with the AGM notice, it must be issued at least 10 days before the meeting is held.  It is also noted in the MUD Act that the AGM must take place within close proximity to the complex and at a reasonable time, unless 75% of the members agree otherwise.  

Sinking Funds of Residential Property Management Companies

Under Section 19 of the MUD Act, residential property management companies are required to establish a ‘Sinking Fund’ to ensure there are adequate resources available to cover ad hoc costs as:
  1. Refurbishment,
  2. Improvement,
  3. Maintenance of a non-recurring nature or,
  4. Advice from suitably qualified person on such work outlined in 1 – 3 above.
Each unit owner within the complex must contribute to the sinking fund on an annual basis, with developers being responsible for any unsold units.  Contributions to the sinking fund are determined and approved by the members at a meeting of the company.  However, if an amount is not agreed upon by the members, the MUD Act outlines that a charge of €200 per unit must then be applied. Furthermore, in order to ensure that contributions to the sinking fund are only used for non-routine costs management companies are required to establish a separate bank account into which all sinking fund contributions must be lodged.  The holding of such monies on deposit may give rise to deposit interest which could have implication on a property management companies claim to Corporation Tax Exemption, which we covered in our recent blog, Corporation Tax Concessions For Residential Property Management Companies.   We understand from our experience of working with residential property management companies that many of the directors appointed to the board are owners of units within the complex and as such they may not be aware of the requirements imposed on them by the MUD Act. While the information required to be presented in an Annual Report may appear to be onerous at the outset, much of the information can be obtained from the company’s annual Financial Statements, with additional information available from insurance and fire safety providers. If you are currently in the process of preparing for your Annual General Meeting and would like to discuss any of the above MUD Act requirements, please do not hesitate to contact a member of our team.   Images: Shutterstock  
November 27, 2014