– Third SEISS Grant introduces “significantly reduced profits” test….

The eligibility criteria for the third SEISS grant have been further tightened, as the guidance for the third Self-employment Income Support Scheme (SEISS) grant has been published, less than one week before the portal opens for claims from 30 November 2020.

On the eve of clients preparing to make a claim, we look at what you need to be aware of.

 

  1. Do I Qualify For The Scheme?
  • You are eligible to claim if you are a self-employed individual or a member of a partnership only;
  • Subject to eligibility, the third and the fourth grants can be claimed even if previous grants were not claimed;
  • You must have been previously eligible for the first and second SEISS grants to claim for the third and fourth grants;
  • The business needs to not only be adversely affected due to coronavirus but also to
    • be currently trading but be impacted by reduced demand due to coronavirus; or
    • have been trading but be temporarily unable to do so due to coronavirus.
  • Guidance published this week now requires you to certify
    • You intend to continue to trade; and
    • reasonably believe there will be a significant reduction in your trading profits due to reduced activity, capacity or demand or inability to trade due to coronavirus

 

  1. Over What Period Am I Required To Review My Eligibility?
  • the significant reduction in trading profits test is to be applied to the accounting period as a whole;
  • For many taxpayers, for example, those that use a 31 March or 5 April accounting date, the significant reduction of trading profits will be expected to appear in the results they report on their 2020/21 tax return.
    • However, some taxpayers, for example, those that use a 30 April accounting date, will not report the trading results for the relevant period until their 2021/22 tax return.

 

  1. So What Am I Expected To Consider?
  • As the significant reduction in trading profits test applies to the tax year as a whole, you should forecast the remainder of your trading results for the year to seek to validate that you will incur a significant reduction in profits over the accounting period covering your claim;
  • Given the complexity of this process, it seems that HMRC are reliant upon an honest assessment from you although you must be aware of the possibility that any claim you make under the scheme may be retrospectively reviewed and enquired into.
  • If in doubt, please contact one of the Partners or your regular Account Manager.