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  • #1222794
    Mattcann
    Participant
    • Total posts: 2

    This might be known already by some, but I had concerns about ongoing eligibility for the job keeper benefit and the detail of the monthly reporting specifically the forecasting of the next months revenue and the possible consequences if you got the forecast wrong.

    Below is from the explanatory document
    https://www.legislation.gov.au/Details/F2020L00419/Download

    “The information provided as part of this report does not affect an entity’s eligibility, including in respect of the decline in turnover test (which only needs to be satisfied once). It is also not intended to verify whether the projection given as part of the decline in turnover test was accurate. Rather, it is intended to ensure that there is good information on which to assess the economic impact of the Coronavirus on a monthly basis across Australia.”

    #1222795
    James Millar
    Participant
    • Total posts: 1,703
    Mattcann, post: 269461, member: 117423 wrote:
    This might be known already by some, but I had concerns about ongoing eligibility for the job keeper benefit and the detail of the monthly reporting specifically the forecasting of the next months revenue and the possible consequences if you got the forecast wrong.

    Below is from the explanatory document
    https://www.legislation.gov.au/Details/F2020L00419/Download

    “The information provided as part of this report does not affect an entity’s eligibility, including in respect of the decline in turnover test (which only needs to be satisfied once). It is also not intended to verify whether the projection given as part of the decline in turnover test was accurate. Rather, it is intended to ensure that there is good information on which to assess the economic impact of the Coronavirus on a monthly basis across Australia.”

    Yes but employers will be held accountable if they had no basis for their projection. ie if it turns out to be off the mark and they have inadequate justification and evidence for the forecast at that time it was made.

    That is why strategically a monthly forecast might be safer than quarterly at the moment. Because it’s not a misrepresentation if March 2020 month or April 2020 were actually lower than the same month 2019 but make no representations about subsequent months – you can’t be held accountable for what happens in those subsequent months as they aren’t part of your forecast period. That still doesn’t allow contrived arrangements it merely reduces risk of a turnaround. EG if a cafe assesses for a March or April decline and passes and then in May govt says you can reopen and back to usual. If you forecast June 2020 quarter to drop and it doesn’t then you may be held accountable for entire forecast period (although the forecast was arguably still reasonable based on info at the time). However if you forecast or actual March or April 2020 drop then it doesn’t matter what happens after that.

    Helping build better businesses and better lives with expert financial and taxation advice. info@360partners.com.au www.360partners.com.au 03 9005 4900
    #1222796
    Mattcann
    Participant
    • Total posts: 2

    Thanks James, your insights and videos have been very useful to me lately.
    I’m very confident of showing a downturn well in excess of 30% for March and April 2020 but I was concerned if got the ongoning monthly reporting incorrect, it would be held against me in some fashion. I’m glad to see that, that is not the case to the best of my understanding as long as it is not part of the original turnover test.

    #1222797
    James Millar
    Participant
    • Total posts: 1,703

    Newsflash

    The Federal Government have today released their legislative guidance for the JobKeeper alternative decline in revenue test.

    There are seven different scenarios they have outlined where an entity may use the alternative test periods rather than the same comparable period 12 months ago as required by the basic decline in revenue test.

    The broad scenarios are

    1. A newly commenced business

    2. A business acquisition or disposal event that changed the entities turnover

    3. A business restructure that changed the entities turnover

    4. A business that experienced a substantial increase in turnover during the last 12 months.

    5. A business affected by drought or natural disaster

    6. A business with an irregular turnover

    7. A sole trader or small partnership with sickness, injury or leave

    These additional options should provide greater access to the JobKeeper program.

    Number four is very helpful for businesses that have improved within the 12 month window.

    Helping build better businesses and better lives with expert financial and taxation advice. info@360partners.com.au www.360partners.com.au 03 9005 4900
    #1222798
    James Millar
    Participant
    • Total posts: 1,703

    Legislation for this in detail here

    https://www.legislation.gov.au/Details/F2020L00461

    Helping build better businesses and better lives with expert financial and taxation advice. info@360partners.com.au www.360partners.com.au 03 9005 4900
    #1222799
    bb1
    Participant
    • Total posts: 4,485
    JamesMillar, post: 269520, member: 5318 wrote:
    Number four is very helpful for businesses that have improved within the 12 month window.


    James I am normally one to read the legislation (it’s a concern), but to save me the hassle, what is the definition of substantial in the case of number 4.
    #1222800
    James Millar
    Participant
    • Total posts: 1,703
    bb1, post: 269522, member: 53375 wrote:
    James I am normally one to read the legislation (it’s a concern), but to save me the hassle, what is the definition of substantial in the case of number 4.

    Excellent question Bert. Extracted here however I’m getting my head around the calculation for the increase of 50%. Not entirely clear what the elements of that “increase calculation” are.

    9. Business had substantial increase in turnover

    (1) An entity applies the alternative test under this section if the entity had an increase in turnover of:

    (a) 50% or more in the 12 months immediately before the applicable turnover test period, or

    (b) 25% or more in the 6 months immediately before the applicable turnover test period, or

    (c) 12.5% or more in the 3 months immediately before the applicable turnover test period.

    (2) The alternative test is:

    (a) if the relevant comparison period is a calendar month, the entity divides the 3 months’ current GST turnover by 3 and uses that figure instead of the entity’s current GST turnover in section 8 of the Rules, or

    (b) if the relevant comparison period is a quarter, the entity uses the 3 months’ current GST turnover instead of the entity’s current GST turnover in section 8 of the Rules.

    (3) The 3 month’s current GST turnover is the total current GST turnover in the 3 months immediately before the applicable turnover test period.

    (4) For the purposes of subsection (3), if the entity:

    (a) qualified for the ATO’s Bushfires 2019–2020 lodgment and payment deferrals, use the 3-month period before the Bushfires 2019–2020 lodgment and payment deferrals commenced to calculate the 3 months’ turnover, or

    (b) received Drought Help concessions, use the 3 month period before this concession commenced to calculate the 3 months’ turnover.

    Helping build better businesses and better lives with expert financial and taxation advice. info@360partners.com.au www.360partners.com.au 03 9005 4900
    #1222801
    James Millar
    Participant
    • Total posts: 1,703

    Getting a bit tired of this jobkeeper – down the rabbit hole again with another piece of new law that is poorly explained (you would think the explanatory statement would contain an example). I’m sure something will be on ATO website soon

    Helping build better businesses and better lives with expert financial and taxation advice. info@360partners.com.au www.360partners.com.au 03 9005 4900
    #1222802
    beemr
    Member
    • Total posts: 6

    So regarding JobKeeper… If your books show >30% decrease in GST revenue for the single month of April 20 vs April 19, you would be eligible for the whole 6 months of JobKeeper payments? Even if you do quarterly BAS, and your quarterly revenue is the same or greater than the previous year? ie, just had a bad April.

    #1222803
    James Millar
    Participant
    • Total posts: 1,703
    beemr, post: 269537, member: 114232 wrote:
    So regarding JobKeeper… If your books show >30% decrease in GST revenue for the single month of April 20 vs April 19, you would be eligible for the whole 6 months of JobKeeper payments? Even if you do quarterly BAS, and your quarterly revenue is the same or greater than the previous year? ie, just had a bad April.
    Correct provide your figures were not manipulated
    Helping build better businesses and better lives with expert financial and taxation advice. info@360partners.com.au www.360partners.com.au 03 9005 4900
    #1222804
    beemr
    Member
    • Total posts: 6
    JamesMillar, post: 269542, member: 5318 wrote:
    Correct provide your figures were not manipulated

    Right, so just to 100% confirm this… you only need to qualify for a single month, or whatever comparison period works best for you. Whatever happens after that, say May/June is irrelevant, even if turnover for those months is back to normal.

    I’m on track to have a pretty bad April but will have cash coming in for May on 60 day accounts. Combine that with some extra advertising i may be on track for a more normal May/June… I just don’t want to jeopardise the JobKeeper payments though, since i do qualify for April onwards.

    #1222805
    James Millar
    Participant
    • Total posts: 1,703
    beemr, post: 269543, member: 114232 wrote:
    Right, so just to 100% confirm this… you only need to qualify for a single month, or whatever comparison period works best for you. Whatever happens after that, say May/June is irrelevant, even if turnover for those months is back to normal.

    I’m on track to have a pretty bad April but will have cash coming in for May on 60 day accounts. Combine that with some extra advertising i may be on track for a more normal May/June… I just don’t want to jeopardise the JobKeeper payments though, since i do qualify for April onwards.

    Correct. Provided your figures demonstrate a legitimate decline in trade over the test period and comparison period then your are into the scheme and there is no requirement to retest or withdraw

    Helping build better businesses and better lives with expert financial and taxation advice. info@360partners.com.au www.360partners.com.au 03 9005 4900
    #1222806
    beemr
    Member
    • Total posts: 6
    JamesMillar, post: 269544, member: 5318 wrote:
    Correct. Provided your figures demonstrate a legitimate decline in trade over the test period and comparison period then your are into the scheme and there is no requirement to retest or withdraw

    Thanks for the info James… So i just made the ‘declaration’ for April. I noticed it says you have to reconfirm eligibility each month. What does this mean exactly? I get that you enter current and projected GST turnover figures monthly (which specifically state is not a ‘retest’ for eligibility). So what is this monthly eligibility confirmation they are talking about?

    #1222807
    James Millar
    Participant
    • Total posts: 1,703
    beemr, post: 269633, member: 114232 wrote:
    Thanks for the info James… So i just made the ‘declaration’ for April. I noticed it says you have to reconfirm eligibility each month. What does this mean exactly? I get that you enter current and projected GST turnover figures monthly (which specifically state is not a ‘retest’ for eligibility). So what is this monthly eligibility confirmation they are talking about?

    Poor choice of words at the ATO. There is definitely no monthly re-testing for employers eligibility but there are monthly ongoing confirmations required regarding the “eligible employees”. It’s a condition of the program that the employer report this information to the ATO within 7 days after end of each month in order to be reimbursed JobKeeper payments.

    Helping build better businesses and better lives with expert financial and taxation advice. info@360partners.com.au www.360partners.com.au 03 9005 4900
    #1222808
    beemr
    Member
    • Total posts: 6
    JamesMillar, post: 269634, member: 5318 wrote:
    Poor choice of words at the ATO. There is definitely no monthly re-testing for employers eligibility but there are monthly ongoing confirmations required regarding the “eligible employees”. It’s a condition of the program that the employer report this information to the ATO within 7 days after end of each month in order to be reimbursed JobKeeper payments.

    Thank you. I also read that STP for closely held employees has been extended to July 2021. Since we are are a family run business, is STP something we can just ignore until, even though we are now getting the JobKeeper payment?

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