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    A message to our clients: Watch out for HMRC furlough compliance checks

    Earlier this year, HMRC introduced measures to claw back any incorrectly claimed financial support throughout the COVID-19 pandemic, plus interest and in some cases, large penalties to those applicable (see our blog from August which outlines this in more detail).

    Following this announcement, we are now starting to see HMRC compliance checks arrive via letter to investigate some of our clients’ previously submitted furlough claims under the Coronavirus Job Retention Scheme (CJRS).


    What does the investigation include?

    HMRC’s compliance check appears to include a full audit – questioning business type, how the business has been affected through COVID-19, and a review of bank statements and / or BACS confirmations that can demonstrate that any monies received have been paid to employees on furlough. All of this data is then reviewed against RTI submissions.


    A message to our clients…

    We advise all of our clients to keep an eye out for any enquiries that come through, and follow the below steps to help protect your business from any potential investigation:


    Always keep records

    We recommend you keep a full paper trail of your furlough claims to include details of salary calculations and evidence of hours furloughed / worked by the employee.


    Be careful how you respond to HMRC

    There is no requirement in the furlough / Coronavirus Job Retention Scheme legislation that specifies your business needs to have suffered losses due to COVID-19 in order to claim, hence, great care should be taken in responding to HMRC in the right way.


    Speak to us!

    If you receive a HMRC investigation notice, please get in touch with your usual PM+M adviser. We can help you understand your position and identify where you stand in terms of compliance.


    Consider taking out fee protection cover

    If you want to protect your business against the potential cost of dealing with a HMRC investigation and ensure that our costs of representing you will be covered, you might want to consider taking out our optional fee protection insurance. This covers our fees for representing you to ensure you get the best outcome from any enquiry or investigation.


    Get in touch with us today

    If you would like to find out more about our fee protection insurance, or simply seek advice if you have any concerns about anything in the above article, please contact your usual PM+M adviser today.

    Alternatively, get in touch via email at and our team will direct you to the best person to help.



    This information is correct as of 23 November 2020. This blog is for general guidance only. Recipients should not act upon any of the information provided without seeking specific professional advice tailored to your circumstances, requirements or needs. Please contact PM+M before making any decisions based on any matters relating to this blog.

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