Feedback procedure on Corona Emergency Aid (“Corona Soforthilfe”): What to do?

Overview

Corona Emergency Aid (“Corona Soforthilfe”) could be applied for by companies and solo self-employed persons in the period from March 27, 2020 to May 31, 2020.

Starting in mid-June 2021, all Corona Emergency Aid recipients who have not yet submitted a response will receive an email inviting them to submit a response and containing the information and links for submitting a response for North-Rhine-Westphalia Corona Emergency Aid 2020. The sender of this email is noreply@soforthilfe-corona.nrw.de.

Requirement for feedback

The completed response form is also necessary if the emergency aid has already been fully repaid. In this case, Corona Emergency Aid recipients have the option of using an abbreviated feedback form. The “Waiver” field is provided for this purpose in the re-registration form. Any repayment already made can also be indicated there.

The deadline for the submission of the feedback form is October 31, 2021, and the repayment deadline is October 31, 2022.

Who is responsible for the feedback?

The Corona Emergency Aid recipient is responsible for the timely and correct return, since he/she also submitted the application. In this case, the tax advisor – if assigned to perform the accounting – will provide financial information to the immediate aid recipient. The emergency aid recipient making the return has a duty to check all the information provided to him.

Alternatively, the Corona Emergency Aid may instruct its tax advisor to complete and submit the Calculation Aid and Unsubmitted Return to the Corona Emergency Aid Recipient for review and signature.

Original requirements for applying for Corona Emergency Aid

The original requirement for applying for Corona Emergency Assistance was that “…significant funding shortfalls and economic hardship exist as a result of Corona.” This was assumed if

  • more than half of the orders from the period before March 1 had been lost as a result of the Corona crisis (i.e., the volume of the order backlog had more than halved), or
  • sales have more than halved compared to the same month of the previous year (If the application is submitted in April 2020, the month of comparison is April 2019). If the month of the previous year cannot be used (e.g., in case of start-ups), the previous month applies, or
  • the possibilities to generate the revenue have been massively restricted by an official requirement in connection with the COVID-19 pandemic, or
  • available funds are not sufficient to pay the short-term liabilities of the company (e.g. rents, loans for business premises, leasing rates) (= financing shortage) “.

New requirements for applying for Corona Emergency Aid

In addition to the above-mentioned original prerequisites, there is now a requirement that there was a liquidity bottleneck.

Official justification by the district government for the new requirement of liquidity shortage:

Subsidiary Provision II.3 of the grant decision links the revenue shortfall included in the application requirements to the purpose of Corona Emergency Aid. According to this incidental provision, there must be both a decline in sales and a liquidity shortage. Provided that the disbursed emergency aid is not or no longer fully needed to cover the liquidity shortage, the overpaid portion must be repaid even if there is a decline in sales.

How is the liquidity shortage to be calculated?

The liquidity shortage is generally calculated as follows:

Continuous revenue from business operations ./. Continuous commercial material and financial expenses = liquidity shortage.

There is an option of performance-based consideration.

Due to the complexity of the calculation of the liquidity bottleneck, we refer to further information on the re-registration procedure, e.g. to be found on the website of the State of North Rhine-Westphalia.

Is it possible to correct the feedback form? How long must documents be kept?

Corona Emergency Aid recipients then have the opportunity to correct their feedback up to three times within 14 days.
Retention period for the documents on which the feedback is based: 10 years.

Please do not hesitate to contact us if you have any questions regarding the re-registration process, as well as assistance in completing the Corona Emergency Assistance re-registration.

Source: https://www.wirtschaft.nrw/nrw-soforthilfe-2020, Düsseldorf Tax Consultants Association

Photo: Moritz Kindler, Unsplash

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