A Directory of Resources and information to help churches and charities through the COVID-19 Pandemic.
The following list is designed to help church and charity leaders, along with Christian missionaries and other Christian workers to navigate their way through the many emerging resources available during this pandemic. The laws and guidance covered apply in England and Wales. There may be variations for those based in Scotland or Northern Ireland.
We have very briefly summarised each resource and then signposted you to further Stewardship and third party information.
Information is changing daily and you are therefore urged to check that you are viewing the most up-to-date details.
A. Help for Churches and Christian Charities
1. Future re-opening of churches, and wedding celebrations
The Government’s Coronavirus FAQs state that whilst there is no change at present to the closure of churches, their intention is to enable small wedding ceremonies from 1 June.
As with all the necessary coronavirus restrictions on register offices, places of worship and other venues, the Government are looking to ease them as soon as it is safe to do so. It is presently anticipated that subject to places of worship meeting the Government’s COVID-19 secure guidance, they may be able to open, or partially open, from (the earliest) 4 July. This date is of course provisional depending on fulfilment of the Governments 5 tests to ease lockdown.
To that end, they have set up a series of Roadmap Taskforces one of which (led by the Ministry for Housing, Communities and Local Government) will look at reopening places of worship. This Taskforce will work closely with faith leaders and local governments over the coming weeks to go through the practicalities and to develop ways in which they can make these public places COVID-19 Secure.
For more information about the Places of Worship Taskforce, please contact [email protected]
2. Coronavirus Job Retention Scheme (‘Furloughing’)
Designed to protect jobs where falls in funding may put those jobs at risk. Government grant funding for 80% of employees’ pay. Available to churches and charities where staff are paid under PAYE. Includes office holders such as ministers of religion.
Claims can be made from 20 April in respect of employees on your PAYE payroll on or before 19 March 2020 where an RTI submission notifying payment in respect of that employee has been made to HMRC on or before 19 March 2020. First payments should be paid within six working days following the claim.
The Scheme, initially running until the end of May 2020, has been extended twice by the Government: First, up to 30 June and now, up until the end of October 2020. The Scheme will run as it is now until the end of July. From August, furloughed workers will be able to return to work part time, with employers being asked to pay a percentage towards the salaries of their furloughed staff. More specific information around the new flexible arrangements from August will be made by the end of May.
Latest advice from our partner solicitors
HMRC guidance for employers can be found here and here which includes an online calculator. An updated step-by-step guide claiming guide, which is “clearer and includes recent additions to the process”, can be found here.
HMRC Guidance and the Scheme itself is evolving. One very recent change (May 2020) to help employers to submit claims correctly is to allow partially completed claims to be saved rather than having to submit them immediately.
In terms of frequently seen errors in claims, HMRC offers the following advice:
HMRC are presently working on allowing employers to amend errors in submitted claims. In the meantime, HMRC say that employers should not amend their next claim to reflect any errors that they may have made in a previous one, as this could delay payment. If they spot an error then, where possible, they will contact the employer or their agent to correct the claim.
3. Holiday entitlement and pay during coronavirus (COVID-19)
The Department for Business, Energy and Industrial Support has published an explanation of how holiday entitlement and pay operate during the coronavirus pandemic, where it differs from the standard holiday entitlement and pay guidance. It covers employers’ legal obligations towards both those that have continued to work, as well as those that have been furloughed under the Coronavirus Job Retention Scheme.
The Guidance covers:
4. Government-backed Loan Schemes
The Government has launched several loan schemes designed to finance entities through the difficulties caused by COVID-19. These schemes are overseen by the Government-owned British Business Bank.
Initial eligibility criteria suggested that religious charities would not qualify. It appears that the criteria have since been changed and that now, all charities “are in principle eligible if they satisfy the other eligibility criteria of the Scheme”. Registered charities are exempt from the requirement that 50% of the applicant’s income must be derived from trading activity.
There are two separate but related schemes that are most likely to be of interest to Christian charities, both of which have ‘turnover’ tests. It is not entirely clear what would constitute ‘turnover’ in the charity context but we understand that the banks are using the charity’s gross income.
To be eligible for both schemes, the charity must be based in the UK and have been negatively affected by coronavirus:
CBILS provides loans from £50,001 up to £5m via third party accredited lenders on repayment terms of up to six years, to entities with a turnover of less than £45m. The first 12 months of interest and lender-levied fees are covered by the Government which will guarantee 80% of the borrowing.
More information can be found using the links from here and here.
This scheme provides for loans between £2,000 and £50,000 (up to a maximum of 25% of turnover). The loan can be for up to six years. There are no set-up fees and first 12 months’ of interest payments will be covered by the Government. No repayments need to be made during the first 12 months. The Government will guarantee 100% of the borrowing.
More information can be found using the links from here and here.
5. Statutory Sick Pay (‘SSP’)
HMRC has published guidance on claiming back SSP paid to employees due to COVID-19. SSP for sickness related to coronavirus is payable from the first day of sickness (rather than after the normal four waiting days). The Government will reimburse coronavirus-related SSP to the employer for the first two weeks and has now announced that claims can be made from 26 May 2020.
6. Tax: Expenses and benefits provided to employees during COVID-19
HMRC has published Guidance on tax reliefs and exemptions (and benefits that remain subject to income tax) arising from employees working from home because their workplace has closed or they have been advised to self isolate. Please note that this Guidance does not apply to furloughed workers.
The Guidance, which can be found here, covers issues such as provision of mobile devices and other employer-provided equipment, broadband installation costs, laptops, computers etc, office supplies, employer-provided loans, additional costs of electricity, heating and broadband and hotel and subsistence costs away from home where self isolating.
Update … On 13 May 2020, Jesse Norman, Financial Secretary to the Treasury issued a Written Statement in the House of Commons which changes part of the above Guidance. Currently, the Guidance states that where an employer reimburses expenses for office equipment bought by an employee for use at home during the coronavirus emergency, this is taxable and should be reported on the employers’ PAYE Settlement Agreement. The Written Statement confirms that there will be a temporary tax exemption and National Insurance disregard to ensure that the expense will not attract tax and NICs liabilities provided that two conditions (set out in the Statement apply). This will be backdated to 16 March and will apply for the remainder of the 2020/21 tax year.
HMRC has also published guidance for employers on ‘How to Treat certain expenses and benefits provided to employees during coronavirus (COVID-19)’ including: Living Accommodation; Volunteer fuel and Mileage Costs; Paying or Refunding Transport Costs; Company Car ‘availability’; and how to report these expenses and benefits to HMRC.
7. Statutory Parental Bereavement Pay and Leave
Working parents who lose a child under the age of 18 will receive two weeks’ statutory leave and
Statutory Parental Bereavement Pay, where the death occurred on or after 6 April 2020.
More details can be found here.
Employers can reclaim up to 103% of the cost. More details can be found here.
8. National Minimum Wage / National Living Wage
Although not directly related to the Coronavirus pandemic, employers should not lose sight of
changes to the NMW and NLW that are effective from 1 April 2020.
Details of the current rate can be found here.
9. Protection from eviction by landlord for non payment of rent
The Coronavirus Act 2020, s82, provides that forfeiture of business tenancies for non-payment of
rent cannot be enforced within the period 26 March 2020 to 30 June 2020 inclusive, or a later date if
the Secretary of State extends it.
The Act defines “rent” as being any sum a tenant is liable to pay under the lease, which includes
service charges and insurance rent contributions.
For charities, this can be a relief or a burden! Those of whom are renting property and unable to pay
their rent; landlords will not be able to evict them. Of course, the opposite is true: if your charity has
tenants that rent property from you, you will also not be able to take enforcement action. In all
cases, the rent still falls due and will need to be paid at a later date.
One note of caution: the Act does not prevent landlords from taking other actions such as
Commercial Rent Arrears Recovery (CRAR), making a debt claim, issuing a statutory demand, or
commencing winding-up proceedings. So far in this regard, The Department for Business, Energy and
Industrial Strategy has urged landlords to act in a socially responsible way and to exercise judgement
and discretion with tenants. It remains to be seen if the government will take more proactive steps
to prevent landlords from effectively side-stepping the Act during the lockdown period.
On the other hand, empty properties at this particular point in time will be an unattractive
proposition for landlords!
10. Gift Aid and the Gift Aid Small Donations Scheme
The Government has agreed to temporarily enable attendees of events that have been cancelled as a result of COVID-19 to be allowed to donate their event ticket price to the hosting charity, under Gift Aid, without the need for the price paid to be refunded to the ticket holder first. There are conditions that have to be met, which are set out in HMRC’s Guidance here.
Note that the relaxation only applies to cancelled and not postponed events.
“In respect of GASDS, guidance on the eligibility for donations for inclusion in this scheme is clear in stating that claims can only be made on cash donations of £30 or less; and contactless card donations of £30 or less collected on or after 6 April 2019.
“The decision over what constitutes an eligible donation is one for the church/charity to make for themselves, rather than for HMRC, but the conditions for something to be considered a ‘small donation’ are clearly set out in legislation. Where it is the case, for example, of separate donations being given in a single envelope, then if the church/charity official is happy these are clearly separate ‘small donations’ (and clearly stated as such) then they will be eligible for GASDS, as is the case where separate envelopes are used.”
This leaves some ambiguity as to what will or will not be permitted. Churches are therefore advised to encourage taxpaying donors to set up standing orders or other forms of digital giving and sign a Gift Aid declaration in the normal way.
“HMRC does not have any statutory discretion to extend filing deadlines and in any case, we think it is likely that most tax-payers will be able to file their returns and/or claims on time. However, if a charity is unable to file a tax return on time or submit a claim, and this is because of the impact of COVID-19, HMRC will consider this in line with the normal ‘reasonable excuse’ process.”
The message therefore, is if you are likely to have problems, contact HMRC as early as possible and keep copies of any correspondence (including email) and make a written record of any telephone conversations noting the date of the call and the name of the HMRC officer concerned.
11. Deferring payments of tax due
There are several schemes available to charities who will have difficulty meeting their tax payment
obligations:
12. Guidance for employers and businesses during COVID-19
Government guidance for staying open safely during the pandemic - summary advice to follow to protect employees and customers, whilst continuing to operate. This includes social distancing, hygiene, cleanliness, staff sickness advice and staying at home.
The Government has started to ease the lockdown and, to facilitate this, they have published a series of Eight Guidance Notes on creating a COVID Secure workplace. These cover (amongst others) outdoor work, offices and contact centres, people working in, visiting or delivering to other people’s homes, restaurants offering takeaway or delivery services and shops.
Employers are reminded of their legal duty to protect the health and safety of their employees and workers. On this theme, the Government has also published a series of Coronavirus Outbreak FAQs. Useful sections for employers include ‘Who is allowed to go to work?’; ‘Do people need to wear face coverings at work’ and sections on Workers’ Rights and Public Transport.
13. Business Rates: Cash grants and extended rates relief for retail, leisure and hospitality sectors
(England; see separate guidance for Wales, Scotland and Northern Ireland)
These reliefs can, potentially, apply to charity shops, coffee shops and certain trading subsidiaries of
churches and charities that are subject to business rates, even if they qualify for charity relief from
those rates.
It applies to properties wholly or mainly used for (amongst other things) shops, restaurants, cafés,
drinking establishments, cinemas, live music venues, assembly and leisure, hotels, guest and
boarding premises.
There are two forms of relief:
Charities that qualify for mandatory 80% rates relief still qualify for these grants even if they
also receive 20% discretionary rates relief.
Summary guidance from the Charity Tax Group can be found here.
Both reliefs are being administered by local authorities and should be paid automatically. There is
only need to contact the LA if a church or charity considers that they should qualify and don’t receive
the relief.
14. Coronavirus, contracts: cancellation and refunds
The Competition and Markets Authority has published useful guidance on the subject of consumer facing businesses responsibilities where contracts are cancelled because of the pandemic. Churches and other venues should be aware of expectations in this area in respect of weddings, conferences, children’s nursery places and the like.
The guidance explains how the law operates in this area and is designed to help consumers understand their rights and to help businesses treat their customers fairly.
For completeness, on 7 May 2020, the Cabinet Office published “Guidance on responsible contractual behaviour in the performance and enforcement of contracts impacted by the Covid-19 emergency”. The Guidance is non-statutory and covers issues in very broad terms. Somewhat repetitively it asks contracting parties to act “responsibly and fairly”. Nevertheless, it is worth being aware where negotiation is needed on a contract impacted by COVID-19. Whilst being non-statutory, parties that choose to ignore it risk reputational damage going forwards.
15. VAT on digital publications and on supplies of essential PPE
From 1 May 2020, supplies of certain digital publications (such as charity members’ magazines) are permanently zero rated for VAT purposes. Supplies prior to this date were standard rated (20%) in contrast to paper equivalents of the same publications which have always been zero rated.
From the same date, supplies of essential personal protective equipment (‘PPE’) are also zero rated for a temporary period of three months.
16. Business Rates: Empty Property Relief
Charities liable to business rates but who are unable to benefit from the Extended Relief for retail
etc premises, above, should give consideration to a claim for Empty Property Relief where this
results from Government instructions to close the premises.
17. COVID-19 Small Business Grant Fund (‘SBGF’)
The SBGF is available to businesses in England in receipt of either Small Business Rates Relief or Rural Rates Relief giving rise to a payment of £10,000. However, as charities benefit from 80% mandatory rates relief (and in come cases and additional 20% discretionary relief), they do not qualify for SBGF.
However, the Government announced (2 May 2020) a Top Up to Local Business Grant Funds Scheme. This is a discretionary fund to accommodate certain small businesses otherwise outside the scope of the SBGF. Funds will be provided to local authorities for them to use locally on a discretionary basis to assist small businesses with ongoing fixed property-related costs. The Government is asking local authorities to prioritise, amongst others, small charity properties that would meet the criteria for Small Business Rates Relief.
More details can be found here and here (with particular reference to Paragraph 24).
18. Risk of fraud and cybercrime against charities during COVID-19
The Government has once again warned that fraudsters are exploiting the spread of coronavirus (COVID-19) in order to carry out fraud and cybercrime. Police have reported an increase in COVID-19-related scams. They state that all charities, but especially those providing services and supporting local communities during the COVID-19 crisis, could be targeted by fraudsters.
The Alert gives examples of the types of fraud circulating, protection measures that can be taken and how to report fraud and cybercrime to the relevant authorities.
19. Food charities and community groups
The Government has announced a £16 million fund to provide food for those who are struggling as a result of coronavirus. The programme will run for 12 weeks from 8 May 2020 and it is said that at least 5,000 frontline charities and community groups in England will benefit, including refuges, homeless shelters and rehabilitation services. It will cover rural areas as well as cities, targeting those who are struggling to get food.
20. Charities supporting victims of domestic abuse or homelessness
The Ministry of Housing, Communities and Local Government has announced £16 million of funding for charities working with victims of domestic abuse and homelessness:
B. Help for self-employed Christian Missionaries and other Christian
Workers
Christian workers who are self employed and rely on raising their own support will ordinarily be
liable to income tax on funds raised because of their Christian work.
1. Self Employed Income Support Scheme and welfare benefits for the self employed
For the self employed that have lost income as a result of COVID-19, the scheme will provide a
taxable grant worth 80% of profits up to a maximum of £2,500 per month for the next three
months.
To confirm eligibility for the scheme, click here and enter your Self Assessment UTR and NI number. The system will tell you if you are eligible. Money will be paid into eligible claimants’ bank accounts within six working days of completing a claim.
Tax agents should not claim under the SEIS for their clients. If they do, it will trigger a fraud alert on HMRC systems and the client will need to contact HMRC to resolve this. It will inevitably delay payment.
Equally, if a third party contacts you offering to help you claim, it is a scam. Do not click on any links; only you can claim. It is a simple process and HMRC will calculate the amount payable for you, using information that they already hold.
HMRC has published a useful guide, with examples, as to how to calculate profits and total income.
The Government has confirmed that people who cannot work their normal hours because of coronavirus (COVID-19) will still receive their usual tax credits payments. Note: this applies to both the self employed and employed workers who have been furloughed.
More information can be found here.
DWP has published a guide on how to report your earnings from self employment for Universal
Credit purposes.
2. Deferral of Self Assessment tax payments
Self Assessment payments on account due on 31 July 2020 can be deferred until 31 January 2021.
There will be no penalties or interest on late payment. Deferral is automatic and applies to any Self
Assessment taxpayers but according to HMRC, if you are able to pay on 31 July 2020, you should do
so.
3. Protection from eviction from rented and mortgaged accommodation
Under the Coronavirus Act 2020, no tenant in social or private accommodation can be forced out of
their home as landlords will not be able to take any court action against a tenant for non payment of
rent for 90 days from 27 March 2020.
Furthermore, landlords will now have to give all tenants three months’ notice (instead of two) if they
intend to seek possession (i.e. serve notice that they want to end the tenancy). This extended period
will apply in law until 30 September 2020 and both the end point and the three-month notice period
can be extended if needed.
This protection covers most tenants in the private and social rented sectors in England and Wales,
and all grounds of evictions. This includes possession of tenancies in the Rent Act 1977, the Housing
Act 1985, the Housing Act 1996 and the Housing Act 1988. If the tenant has not moved after three
months, the landlord needs to apply to court in order to proceed.
The suspension of housing possession cases will also apply to possession cases brought by
mortgagees against homeowners, and to possession cases brought by landlords against leaseholders
(forfeiture).
Additional information can be found here and here.
C. Help for individuals and Workers
1. Easing lockdown: General help
As the Government has begun to ease the lockdown, there has been uncertainty in many people’s minds around what they can or cannot do and what they should or shouldn’t do.
The Government has published a series of Coronavirus Outbreak FAQs which cover topics such as: Public Spaces and Outdoor Exercise (which includes some helpful guidance on ‘What can I do that I couldn’t do before? [13 May 2020]; Going to Work / Safer Spaces (which includes guidance on who is or isn’t currently allowed to go to work and the issue of face coverings); Workers Rights; Public Transport; and Schools and Childcare amongst other areas.
From this, there are links to other forms of guidance such as:
2. Tax-Free Childcare and 30 hours free childcare
On 7 May, the Government published temporary changes to the eligibility criteria for Tax-Free Childcare and 30 hours free childcare, during coronavirus. The changes may affect you if you, or someone you live with, are:
More details can be found here.
3. Help for low-income families with seriously ill or disabled children
The Government has announced over £37 million of funding to help low-income families with seriously ill or disabled children with the cost of equipment, goods or services. Of the total amount, £10 million has been committed to the unique difficulties presented by the COVID-19 pandemic, helping parents educate and look after disabled or critically ill children who are staying at home more than usual.
Families with children that have complex needs and disabilities will be eligible for grants through Family Fund for vital equipment to make their lives easier while implementing social distancing measures, including computers, specialist equipment and educational toys.
4. HMRC advice on giving up employment or investment income during COVID-19
HMRC is urging people to check the tax rules on waiving income or donating to charity. It is aimed at those who choose to give up some of their income to support their business or donate to charity during the COVID-19 pandemic. In some cases, in order to keep the business going, it may not possible to furlough all staff. It may, therefore, be necessary for directors and staff to consider taking a pay cut and a waiver of salary is one way to achieve this.
There is a right way and a wrong way to do these things! The guidance should help avoid a situation where tax and national insurance is still payable even though the waived income is never received. It covers salaries, bonuses and dividends that are either waived or paid back after receipt.
5. Scams: Scammers taking advantage of the coronavirus (COVID-19) pandemic
HMRC is reporting that, so far, they have detected more than 70 COVID-19-related financial scams, and have asked Internet Service Providers to take down over 400 web pages associated with these scams.
Mimicking government communications, one of the new scams says that it has ‘identified you as a candidate for the Key Worker Rebate’.
They are urging people to check GOV.UK for information on how to recognise genuine HMRC contact and how to avoid and report scams. Suspicious emails claiming to be from HMRC should reported to: [email protected] Texts should be sent to 60599.
Other General Resources / Signposts
Charity Tax Group - Coronavirus Hub for charity tax and finance professionals
Charity Excellence Framework - COVID-19 Funder list - Many, many potential grant funders (local,
national and international). Register for free access to the searchable database from the link on this page.
NCVO – A list of funding opportunities for charities including brief details of grant criteria.
London Funders – has coordinated a list of over 250 Grant Funders that have pledged to stand with the Charity Sector during the COVID-19 pandemic and to operate in a flexible way to support the sector at this time.
HMRC - HMRC has a number of webinars and YouTube videos on the various business support
packages, including the deferral of VAT and Income Tax payments, the Coronavirus Job Retention
Scheme and the HMRC Time to Pay Scheme.
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