In response to relevant enquiries and questions raised by the general public as to the practical application of the Fiscal Measures offered bby the Govenrment, further announcements have been made by the Minister of Employment, Welfare and Social Insurance. The key items to note are:
- Partial Suspension of Business and Self-employed Persons: in order for a company or self-employed person to calculate the reduction in turnover, any transactions that took place before the 16th March 2020 will not be counted in the estimation of turnover (even if the invoice had been raised after the 16thMarch 2020 or if payment had been received after the 16th March 2020).
- Groups of companies: for Groups of companies (i.e. relationship between mother company and a subsidiary or connected company via a common shareholder) with separate/unique Employer's Registration with the Social Insurance Numbers, all applications per Employer's Registration Number for the full and/or partial suspension schemes will be considered as one application and the terms of the scheme(s) will be applied as though the Employer Registration Number was unified. It should be noted that, for this to apply, all companies in the Group have to be engaged in the same activities (e.g. retail chain with many brands/companies, food chains with different brands, Group of restaurants with each restaurant being a different company and so on).
- Companies which are single legal entities, but have more than one Employer's Registration Number with the Social Insurance will be treated as though they have a single Employer's Registration Number, regardless of whether their applications have been submitted per Employer Registration Number. Their treatment as one employer will concern the full and partial suspension plans.
- Companies whose operations are connected to those companies that shut down due to the Minister of Health Decrees will also be entitled to participate to the full work suspension plan, if they have experienced more than 80% reduction in turnover (as this is calculated based on the relevant guidelines).
- Employees who did not have insurable units within 2018 and are therefore entitled to receive the special unemployment allowance based on their insurable income of January 2020 (or earlier in case this does not apply) will be entitled to 40% of their insurable income and not 60%.
- All applications will be treated in a first come – first served basis, provided that employees insert their banking data/IBAN in the system and the applications are properly filled.
- All the aforementioned apply retrospectively, as of the 16th March 2020.
Originally published 08 April 2020
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