HM Courts & Tribunals Service (HMCTS) has published detailed guidance on how and when to report payments made to employees via the Coronavirus Job Retention Scheme (CJRS) using the PAYE Real Time Information system.
The guidance published on 23 April 2020, provides that any grants paid to employers through the CJRS should be treated in the same way as any wage payment and that employees should continue to be paid in accordance with their contractual payment date.
Where employers have paid wages prior to the contractual payment date, they must ensure that the next payment is to be made on the usual contractual payment date.
The guidance also addresses scenarios for employers who are using the grant to reimburse wages already paid. If employers have continued to pay their employees before receiving the grant, they will have complied with the rules and therefore, there will be no requirement for employers to make another full payment submission as the furlough grant will be reimbursing the wages that have already been reported by the employer.
In the instance employers have not paid any of their employees’ full wages yet, the guidance sets out that they are required to submit an Employer Payment Submission which states they have not paid employees in that tax month. The Employer Payment Submission should be sent no later than 19th day of the following tax month where possible.
Where an employer only pays 20% of their employees’ normal wage until the grant is received, employers must deduct any tax and National Insurance contributions due on the reduced salary payment amounts and must further report these payments by submitting a Full Payment Submission to HMRC, on or before the payment dates. Employers must only send a Full Payment Submission reporting the payments that were actually made. Once employers pay the remaining wages employees after receiving the grant payment, they must send another Full Payment Submission showing that payment.
The guideline further sets out that if an employer is making a payment for March and April in employee wages, they must deduct tax and National Insurance Contributions on the full amount. Employers must ensure not to back date the March payment.
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