JobKeeper Payment Information

JobKeeper Overview

The government has introduced a $130 billion JobKeeper Payment scheme to support businesses significantly affected by the coronavirus to help keep more Australians in jobs. 

The JobKeeper payment is open to eligible employers to enable them to pay their eligible employee’s salary or wages of at least $1,500 (before tax) per fortnight. 

Eligible employers will be reimbursed a fixed amount of $1,500 per fortnight for each eligible employee. 

Employers will need to pay eligible employees a minimum of $1,500 (before tax) per fortnight to claim the JobKeeper payment. This will be paid to the employer in arrears each month by us (ATO). The first payments to eligible employers will commence in the first week of May 2020. JobKeeper payments can be made for the period beginning 30 March 2020. 

If employers do not continue to pay their employees for each pay period, they will cease to qualify for the JobKeeper payment. 

To be eligible for the JobKeeper payment, employers and their employees must meet a range of criteria.

Read more: https://www.ato.gov.au/general/JobKeeper-Payment  

Extension of time to enrol for the JobKeeper scheme

The Commissioner has extended the time to enrol for the initial JobKeeper periods, from 30 April 2020 until 31 May 2020.

If you enrol by 31 May 2020, you will still be able to claim for the JobKeeper fortnights ending in April and May, provided you meet all the eligibility requirements for each for those fortnights. This includes having paid your employees by the appropriate date for each fortnight.

For the first two fortnights (30 March – 12 April, 13 April – 26 April), we will accept the minimum $1,500 payment for each fortnight has been paid by you even if it has been paid late, provided it is paid by 8 May 2020. If you do not pay your staff by this date, you will not be able to claim JobKeeper for the first two fortnights.

You can enrol and claim for JobKeeper earlier if you choose. For example, you can enrol by the end of April to claim JobKeeper payments for the two fortnights in April.

JobKeeper Guidance for NSW P&C Associations

(This guidance is based on a discussion with the ATO as at 26 April 2020. While P&C Federation offers this analysis based on our understanding, P&C Federation encourages all P&C Associations to seek professional advice with regards to your P&C Association’s circumstances and structure. For further clarifiation regarding your P&C Association’s particular situation, P&C Federation advises you contact the ATO for advice.)

The JobKeeper payment is intended to assist businesses, including P&C Associations, affected by COVID-19 to cover the costs of wages of their employees.  It is only relevant to P&Cs that have employees, either permanent or casual.  Additionally, if all of a P&C’s potentially eligible employees are already participating in the JobKeeper scheme through another employer there is no reason for a P&C to further investigate the scheme.  No employee can participate in the JobKeeper scheme through more than one employer.

The JobKeeper scheme starts on 30 March 2020 and ends on 27 September 2020.

A business that has suffered a substantial decline in turnover can be entitled to a JobKeeper payment of $1,500 per fortnight for each eligible employee. It is a condition of entitlement that the business has paid gross salary and wages of at least that amount to the employee in the fortnight, even where that amount is greater than the employee’s normal pay. 

The Australian Taxation Office (ATO) reimburses the business for JobKeeper payments at a rate of $1,500 per fortnight per participating employee.  These reimbursement payments are made by the ATO in the calendar month following the month in which the JobKeeper payments are made to employees.   

The JobKeeper scheme, eligibility requirements and processes are described at and from https://www.ato.gov.au/general/JobKeeper-Payment/?=Redirected_URL.

For those interested, the legal specifications of the JobKeeper scheme are at https://www.legislation.gov.au/Details/F2020L00419 with an accompanying explanatory statement at https://www.legislation.gov.au/Details/F2020L00419/Explanatory%20Statement/Text.

This guidance document does not aim to replace the documentation and explanations provided by the ATO at the above link.  The information available from the ATO should be consulted first. 

The purpose of this document is to provide clarifications which are specific to NSW P&C Associations.

Participation in the JobKeeper Scheme

Participation in the JobKeeper scheme is not mandatory.  If a P&C satisfies the employer eligibility requirements, as described at https://www.ato.gov.au/General/JobKeeper-Payment/Employers/Eligible-employers/, it has the option of deciding to enrol, using the process described at https://www.ato.gov.au/General/JobKeeper-Payment/Employers/Enrol-for-the-JobKeeper-payment/.  Enrolment and subsequent reporting processes require a P&C Office Bearer, typically the P&C’s Treasurer, to have a myGovID which enables a login to the P&C’s activity statement records through the ATO’s Business Portal.  Alternatively, a tax agent can act on the P&C’s behalf.    

If a P&C is eligible and decides to participate in the JobKeeper scheme, its employees must be notified and all eligible employees who decide to participate must be included.  An eligible employee cannot be excluded from the scheme once the P&C has decided to participate. Employee eligibility and associated processes are described at https://www.ato.gov.au/General/JobKeeper-Payment/Employers/Your-eligible-employees/.

Employer Eligibility – Reduction in Turnover

One of the employer eligibility tests requires the P&C to confirm that it has experienced or expects to experience a reduction in “GST turnover” (further described below) for a relevant period in 2020 compared to the same period in 2019. 

Once a P&C has established its eligibility to participate in the JobKeeper scheme, all of its employees are potentially eligible to participate, if they satisfy all of the employee eligibility requirements (as described later), even if they work for a part of the P&C that has not had its revenue included in the reduction of turnover test.      

The required reduction in turnover to be eligible for JobKeeper is 15% (or more) of the revenue in the 2019 comparison period if the P&C is registered with the Australian Charities and Not-for-profits Commission (ACNC) as a charity. If a P&C is not registered as a charity (though all P&Cs should be registered charities), the required turnover reduction is 30% (or more).

Once the P&C has established the relevant reduction it has satisfied this reduction in turnover test for the remainder of the period in which JobKeeper payments are made. The P&C does not have to continue to have a reduction in turnover in any later part of the JobKeeper period. 

The following table describes the available comparison periods.

For JobKeeper payments to employees starting in:The corresponding available comparison periods are:
April 2020March 2019 vs March 2020
April 2019 vs April 2020
April-June 2019 vs April-June 2020
May 2020Any month March-May 2019 vs the corresponding month in 2020 OR
April-June 2019 vs April-June 2020
June 2020Any month March-June 2019 vs the corresponding month in 2020 OR
April-June 2019 vs April-June 2020
July 2020Any month March-July 2019 vs the corresponding month in 2020 OR
April-June 2019 vs April-June 2020 OR
July-September 2019 vs July-September 2020
August 2020Any month March-Aug 2019 vs the corresponding month in 2020 OR
April-June 2019 vs April-June 2020 OR
July-September 2019 vs July-September 2020
September 2020Any month March-Sept 2019 vs the corresponding month in 2020 OR
April-June 2019 vs April-June 2020 OR
July-September 2019 vs July-September 2020

Note: The use of some comparison periods will require a projection or estimate of revenue for the period in 2020.


Alternative Tests for Assessing Reduction in “GST turnover”

If there is an anomaly in the revenue for either a 2019 or 2020 comparison period which results in the P&C not showing a sufficient decline in revenue to qualify for JobKeeper eligibility there may be an “alternative test” of revenue reduction available. The circumstances in which an alternative test is available are varied and include situations such as a P&C being newly formed and not having a corresponding period in 2019 or having an unusually low income in the 2019 period or having an irregular or particularly lumpy income which distorts the comparison. The potential and process for applying an “alternative test” is described at https://www.ato.gov.au/General/JobKeeper-Payment/In-detail/Applying-the-turnover-test/?anchor=Alternativetest#Alternativetest.             

Calculation of “GST turnover”

The revenue (or turnover) reduction test is done by comparing the “GST turnover” for the two comparison periods, as described at https://www.ato.gov.au/General/JobKeeper-Payment/In-detail/Applying-the-turnover-test/ .

A business’s “GST turnover” is defined as being the revenue on which it charges GST (or would have charged GST if the business had been registered for GST) but is redefined or extended for JobKeeper purposes to also include certain donations received by not-for-profit organisations (such as P&Cs).  See later for a description of the conditions under which certain donations must be included in the calculation of “GST turnover” for JobKeeper eligibility purposes.

A P&C’s canteen revenue is excluded from the calculation of “GST turnover” because of the provisions of GST law that result in school canteens run by not-for-profit entities (such as all P&Cs) being input-taxed, as described at https://www.ato.gov.au/non-profit/your-organisation/gst/gst-concessions/#schooltuckshops.  (While this ATO guidance states that a P&C has to choose to operate a canteen as input-taxed and could instead operate a canteen with GST being charged, no P&C is known to have done this and all P&C-operated canteens are believed to be input-taxed.)

If a P&C is registered for GST and is a charity registered with the ACNC and makes use of the charity tax concessions to create input-taxed sub-entities, as described at https://www.ato.gov.au/Non-profit/your-organisation/gst/gst-branches,-groups-and-non-profit-sub-entities/?anchor=nonprofitsubentities#nonprofitsubentities, then the revenue of those input-taxed sub-entities is excluded from the calculation of “GST turnover”.  Note that under the requirements for being input-taxed, a sub-entity cannot remain input-taxed but must instead charge GST on its sales if its annual revenue exceeds:

  • $150,000 if the P&C is registered as a charity; or
  • $75,000 if the P&C is not registered as a charity.    

The inclusion of revenue from a fundraising event in total “GST turnover” will depend on whether the event has satisfied the criteria described at https://www.ato.gov.au/non-profit/your-organisation/gst/gst-concessions/#fundraisingevent and the P&C decided to treat the event as input-taxed or not, in compliance with the specified requirements.  If the P&C had decided to treat the fundraising event as input-taxed, the associated revenue would be excluded from the calculation of “GST turnover”.  Conversely, if the P&C had not decided to treat the fundraising event as input-taxed (and therefore included GST in any sales revenue associated with the fundraising event), the associated revenue would be included in the calculation of “GST turnover”. 

P&Cs Not Registered for GST

If a P&C is not registered for GST, “GST turnover” is calculated by including all of the revenue that would have included GST had the P&C been registered for GST, and making the assumption that the P&C did not elect to create input-taxed sub-entities, plus adding donations that satisfy the conditions for including donations (as described below).  Canteen revenue remains excluded from “GST turnover” because all P&Cs are assumed to treat canteen revenue as input-taxed.    

A table listing the common sources of P&C revenue and applying the above is included later.

Change in GST Registration Status

If a P&C is registered for GST in one period used for determining the reduction in its turnover and not registered for GST in the other period used for the comparison, it uses the approach applicable to its GST registration status at each separate period. For the period during which the P&C was registered for GST, the P&C’s “GST turnover” excludes the GST component from its revenue. 

Inclusion of Donations in “GST Turnover”

Donations are included in “GST turnover” of a P&C under one but not both of the following conditions:

  1. If the P&C has Deductible Gift Recipient status for a School Building Fund that has the same ABN as the P&C, any donations to the Building Fund in the relevant period are to be included in the total “GST turnover” of the P&C for that period. No other donations received by the P&C are to be included in “GST turnover”.
  1. If the above does not apply and the P&C is registered as a charity with the ACNC then any donations received by the P&C (which, by operation of the previous condition, cannot be donations to a DGR) in the relevant period are to be included in the total “GST turnover” of the P&C for that period.  

If the P&C does not satisfy either of the above conditions then no donation income it receives is to be included in the total “GST turnover” for any period.

However, while the above reflects the current JobKeeper specifications for including or excluding donations in “GST turnover” there is a strong possibility that the above specification will be changed. 

Timing of Donations Received by School on behalf of a P&C Association

Many schools collect donations requested by a P&C as part of a single payment by a parent to the school which also includes voluntary contributions requested by the school and/or subject/material charges.  In this case, where it is either impossible or impractical to determine the date on which the donations to the P&C were made by the various parents, it is reasonable to use the date(s) on which the donations were deposited in the P&C’s bank account (following their transfer by the school) as the date(s) of the donations for the purpose of determining in which period they occur for the turnover reduction test.    

A reasonable approach to determining the date(s) of donations to a P&C where the funds are never transferred to a P&C’s bank account is being investigated.  This situation could occur where a school retains the donations on behalf of a P&C until a sum is approved by the P&C for use by the school, either immediately upon collection or at a later date.  Note that P&C Federation recommends that this approach not be used and that all donations collected on behalf of a P&C should be transferred to the P&C.    

Inclusion or Exclusion in “GST Turnover” of Common P&C Revenue Items

Note: Some P&C Association canteens are registered for GST, however the majority of P&C run canteens are in-put taxed operated.

Revenue item: If the P&C is registered for GST: If the P&C is not registered for GST:
Band program feesExclude if within an input-taxed sub-entity (ie GST is not charged)
Include if not within an input-taxed sub-entity (ie, GST is charged)
Include
Before and after school care feesExclude if within an input-taxed sub-entity (ie GST is not charged)
Include if not within an input-taxed sub-entity (ie, GST is charged)
Include
Canteen salesExclude (If in-put tax operated)
Include (if GST added to products sold)
Exclude
Commission income (eg Entertainment Books)Include (but exclude if made directly to an input-taxed sub-entity with a function which legitimately includes the commission-related activity)Include
Donations and gifts (including donations and gifts to or at a fundraising event)
Refer to earlier explanationRefer to earlier explanation
Fundraising event revenue (excluding donations and gifts)Exclude if fundraising event was treated as input-taxed in line with requirements outlined earlier (ie, GST was not charged)
Include if fund-raising event was not input-taxed (ie GST was charged on ticket sales, etc)
Exclude if the fund-raising event was eligible for the fund-raising event GST concession and the P&C elected to use the concession (as described earlier)
Include if the fund-raising event was not held under the fund-raising event GST concession
Grants – Government (Federal, state or local)Include if the P&C is not a registered charity

Include if the P&C is a registered charity and has not chosen to exclude the grant income

Exclude if the P&C is a registered charity and has chosen to exclude the grant income and has notified the ATO of this exclusion
As for P&Cs registered for GST
Grants - Non-governmentInclude (but exclude if the grant did not include a GST component and was made directly to an input-taxed sub-entity with a function which legitimately includes the grant-related activity)Include
Input-taxed sub-entity revenueExcludeNot applicable: Input-taxed sub-entities can only exist if a P&C is registered for GST
Insurance claimsExclude if for loss within an input-taxed sub-entity
Include if for loss not within an input-taxed sub-entity
Include
Interest and other investment incomeExcludeExclude
Raffles or bingo (ticket sales)Include if the P&C is not a registered charity: the amount to be included is ten elevenths of the difference between total ticket sales and total monetary prizes

Exclude if the P&C is a registered charity
As for P&Cs registered for GST
P&C membership feesIncludeInclude
Uniform shop salesExclude if within an input-taxed sub-entity (ie GST is not charged)
Include if not within an input-taxed sub-entity (ie, GST is charged)
Include

Employee Eligibility

Once a P&C determines it is eligible for JobKeeper as an employer and decides to join the scheme, it must next determine which of its employees are eligible and wish to participate.  The P&C cannot discriminate between its employees.  Once the P&C enrols in JobKeeper all eligible employees who wish to participate must be included as soon as they have completed the necessary forms and sent them to the P&C. The employee eligibility rules and associated processes are described at https://www.ato.gov.au/General/JobKeeper-Payment/Employees/Eligible-employees/.

P&C employees who were employed as at 1 March 2020 and were either permanent employees (part-time or full-time) or long-term casuals (see below for further explanation) are potentially eligible. There are other requirements applying to eligibility of employees and these are further explained at the above link and also on the employee JobKeeper declaration form described and provided at https://www.ato.gov.au/Forms/JobKeeper-payment—employee-nomination-notice/.

Only One Employer Eligible for JobKeeper Payments for the One Person

An employee can only have the JobKeeper payment in respect of one employer.  If a P&C employee also has at least one other employer, the following applies:

  1. If the employee is employed on a permanent basis by one or more employers, the employee chooses which JobKeeper-enrolled permanent employer will receive the JobKeeper payment and otherwise comply with the JobKeeper scheme requirements. If none of the employee’s permanent employers are participating in the JobKeeper scheme, the employee cannot participate in the JobKeeper scheme. Any permanent employment prevents the employee participating on the basis of casual employment with a different employer.
  1. If the employee is not employed on a permanent basis by any employer but is employed on a casual basis by more than one employer and more than one of those employers are participating in the JobKeeper scheme, the employee chooses which JobKeeper-enrolled casual employer will receive the JobKeeper payment and otherwise comply with the JobKeeper scheme requirements.

Eligibility of Long-Term Casual Employees

The JobKeeper scheme provides for the inclusion of “long-term casual employees”.  The criteria for determining whether a casual employee qualifies for JobKeeper are briefly described (at the earlier employee eligibility link) as a casual employee who has been “employed on a regular and systematic basis for at least 12 months as at 1 March 2020”. This is further explained by the ATO as “a casual employee is likely to be employed on a regular and systematic basis where the employee has a recurring work schedule or a reasonable expectation of ongoing work”.

  See https://www.ato.gov.au/General/JobKeeper-Payment/In-detail/Employee-test-requirements/?page=2#Consideredalongtermcasualemployee and the examples listed there.

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JobKeeper Overview

JobKeeper Overview

The government has introduced a $130 billion JobKeeper Payment scheme to support businesses significantly affected by the coronavirus to help keep more Australians in jobs. 

The JobKeeper payment is open to eligible employers to enable them to pay their eligible employee’s salary or wages of at least $1,500 (before tax) per fortnight. 

Eligible employers will be reimbursed a fixed amount of $1,500 per fortnight for each eligible employee. 

Employers will need to pay eligible employees a minimum of $1,500 (before tax) per fortnight to claim the JobKeeper payment. This will be paid to the employer in arrears each month by us (ATO). The first payments to eligible employers will commence in the first week of May 2020. JobKeeper payments can be made for the period beginning 30 March 2020. 

If employers do not continue to pay their employees for each pay period, they will cease to qualify for the JobKeeper payment. 

To be eligible for the JobKeeper payment, employers and their employees must meet a range of criteria.

Read more: https://www.ato.gov.au/general/JobKeeper-Payment  

JobKeeper scheme - Extension of time to enrol

Extension of time to enrol for the JobKeeper scheme

The Commissioner has extended the time to enrol for the initial JobKeeper periods, from 30 April 2020 until 31 May 2020.

If you enrol by 31 May 2020, you will still be able to claim for the JobKeeper fortnights ending in April and May, provided you meet all the eligibility requirements for each for those fortnights. This includes having paid your employees by the appropriate date for each fortnight.

For the first two fortnights (30 March – 12 April, 13 April – 26 April), we will accept the minimum $1,500 payment for each fortnight has been paid by you even if it has been paid late, provided it is paid by 8 May 2020. If you do not pay your staff by this date, you will not be able to claim JobKeeper for the first two fortnights.

You can enrol and claim for JobKeeper earlier if you choose. For example, you can enrol by the end of April to claim JobKeeper payments for the two fortnights in April.

JobKeeper Guidance for NSW P&C Associations

JobKeeper Guidance for NSW P&C Associations

(This guidance is based on a discussion with the ATO as at 26 April 2020. While P&C Federation offers this analysis based on our understanding, P&C Federation encourages all P&C Associations to seek professional advice with regards to your P&C Association’s circumstances and structure. For further clarifiation regarding your P&C Association’s particular situation, P&C Federation advises you contact the ATO for advice.)

The JobKeeper payment is intended to assist businesses, including P&C Associations, affected by COVID-19 to cover the costs of wages of their employees.  It is only relevant to P&Cs that have employees, either permanent or casual.  Additionally, if all of a P&C’s potentially eligible employees are already participating in the JobKeeper scheme through another employer there is no reason for a P&C to further investigate the scheme.  No employee can participate in the JobKeeper scheme through more than one employer.

The JobKeeper scheme starts on 30 March 2020 and ends on 27 September 2020.

A business that has suffered a substantial decline in turnover can be entitled to a JobKeeper payment of $1,500 per fortnight for each eligible employee. It is a condition of entitlement that the business has paid gross salary and wages of at least that amount to the employee in the fortnight, even where that amount is greater than the employee’s normal pay. 

The Australian Taxation Office (ATO) reimburses the business for JobKeeper payments at a rate of $1,500 per fortnight per participating employee.  These reimbursement payments are made by the ATO in the calendar month following the month in which the JobKeeper payments are made to employees.   

The JobKeeper scheme, eligibility requirements and processes are described at and from https://www.ato.gov.au/general/JobKeeper-Payment/?=Redirected_URL.

For those interested, the legal specifications of the JobKeeper scheme are at https://www.legislation.gov.au/Details/F2020L00419 with an accompanying explanatory statement at https://www.legislation.gov.au/Details/F2020L00419/Explanatory%20Statement/Text.

This guidance document does not aim to replace the documentation and explanations provided by the ATO at the above link.  The information available from the ATO should be consulted first. 

The purpose of this document is to provide clarifications which are specific to NSW P&C Associations.

Participation in the JobKeeper Scheme

Participation in the JobKeeper scheme is not mandatory.  If a P&C satisfies the employer eligibility requirements, as described at https://www.ato.gov.au/General/JobKeeper-Payment/Employers/Eligible-employers/, it has the option of deciding to enrol, using the process described at https://www.ato.gov.au/General/JobKeeper-Payment/Employers/Enrol-for-the-JobKeeper-payment/.  Enrolment and subsequent reporting processes require a P&C Office Bearer, typically the P&C’s Treasurer, to have a myGovID which enables a login to the P&C’s activity statement records through the ATO’s Business Portal.  Alternatively, a tax agent can act on the P&C’s behalf.    

If a P&C is eligible and decides to participate in the JobKeeper scheme, its employees must be notified and all eligible employees who decide to participate must be included.  An eligible employee cannot be excluded from the scheme once the P&C has decided to participate. Employee eligibility and associated processes are described at https://www.ato.gov.au/General/JobKeeper-Payment/Employers/Your-eligible-employees/.

Employer Eligibility – Reduction in Turnover

One of the employer eligibility tests requires the P&C to confirm that it has experienced or expects to experience a reduction in “GST turnover” (further described below) for a relevant period in 2020 compared to the same period in 2019. 

Once a P&C has established its eligibility to participate in the JobKeeper scheme, all of its employees are potentially eligible to participate, if they satisfy all of the employee eligibility requirements (as described later), even if they work for a part of the P&C that has not had its revenue included in the reduction of turnover test.      

The required reduction in turnover to be eligible for JobKeeper is 15% (or more) of the revenue in the 2019 comparison period if the P&C is registered with the Australian Charities and Not-for-profits Commission (ACNC) as a charity. If a P&C is not registered as a charity (though all P&Cs should be registered charities), the required turnover reduction is 30% (or more).

Once the P&C has established the relevant reduction it has satisfied this reduction in turnover test for the remainder of the period in which JobKeeper payments are made. The P&C does not have to continue to have a reduction in turnover in any later part of the JobKeeper period. 

The following table describes the available comparison periods.

For JobKeeper payments to employees starting in:The corresponding available comparison periods are:
April 2020March 2019 vs March 2020
April 2019 vs April 2020
April-June 2019 vs April-June 2020
May 2020Any month March-May 2019 vs the corresponding month in 2020 OR
April-June 2019 vs April-June 2020
June 2020Any month March-June 2019 vs the corresponding month in 2020 OR
April-June 2019 vs April-June 2020
July 2020Any month March-July 2019 vs the corresponding month in 2020 OR
April-June 2019 vs April-June 2020 OR
July-September 2019 vs July-September 2020
August 2020Any month March-Aug 2019 vs the corresponding month in 2020 OR
April-June 2019 vs April-June 2020 OR
July-September 2019 vs July-September 2020
September 2020Any month March-Sept 2019 vs the corresponding month in 2020 OR
April-June 2019 vs April-June 2020 OR
July-September 2019 vs July-September 2020

Note: The use of some comparison periods will require a projection or estimate of revenue for the period in 2020.


Alternative Tests for Assessing Reduction in “GST turnover”

If there is an anomaly in the revenue for either a 2019 or 2020 comparison period which results in the P&C not showing a sufficient decline in revenue to qualify for JobKeeper eligibility there may be an “alternative test” of revenue reduction available. The circumstances in which an alternative test is available are varied and include situations such as a P&C being newly formed and not having a corresponding period in 2019 or having an unusually low income in the 2019 period or having an irregular or particularly lumpy income which distorts the comparison. The potential and process for applying an “alternative test” is described at https://www.ato.gov.au/General/JobKeeper-Payment/In-detail/Applying-the-turnover-test/?anchor=Alternativetest#Alternativetest.             

Calculation of “GST turnover”

The revenue (or turnover) reduction test is done by comparing the “GST turnover” for the two comparison periods, as described at https://www.ato.gov.au/General/JobKeeper-Payment/In-detail/Applying-the-turnover-test/ .

A business’s “GST turnover” is defined as being the revenue on which it charges GST (or would have charged GST if the business had been registered for GST) but is redefined or extended for JobKeeper purposes to also include certain donations received by not-for-profit organisations (such as P&Cs).  See later for a description of the conditions under which certain donations must be included in the calculation of “GST turnover” for JobKeeper eligibility purposes.

A P&C’s canteen revenue is excluded from the calculation of “GST turnover” because of the provisions of GST law that result in school canteens run by not-for-profit entities (such as all P&Cs) being input-taxed, as described at https://www.ato.gov.au/non-profit/your-organisation/gst/gst-concessions/#schooltuckshops.  (While this ATO guidance states that a P&C has to choose to operate a canteen as input-taxed and could instead operate a canteen with GST being charged, no P&C is known to have done this and all P&C-operated canteens are believed to be input-taxed.)

If a P&C is registered for GST and is a charity registered with the ACNC and makes use of the charity tax concessions to create input-taxed sub-entities, as described at https://www.ato.gov.au/Non-profit/your-organisation/gst/gst-branches,-groups-and-non-profit-sub-entities/?anchor=nonprofitsubentities#nonprofitsubentities, then the revenue of those input-taxed sub-entities is excluded from the calculation of “GST turnover”.  Note that under the requirements for being input-taxed, a sub-entity cannot remain input-taxed but must instead charge GST on its sales if its annual revenue exceeds:

  • $150,000 if the P&C is registered as a charity; or
  • $75,000 if the P&C is not registered as a charity.    

The inclusion of revenue from a fundraising event in total “GST turnover” will depend on whether the event has satisfied the criteria described at https://www.ato.gov.au/non-profit/your-organisation/gst/gst-concessions/#fundraisingevent and the P&C decided to treat the event as input-taxed or not, in compliance with the specified requirements.  If the P&C had decided to treat the fundraising event as input-taxed, the associated revenue would be excluded from the calculation of “GST turnover”.  Conversely, if the P&C had not decided to treat the fundraising event as input-taxed (and therefore included GST in any sales revenue associated with the fundraising event), the associated revenue would be included in the calculation of “GST turnover”. 

P&Cs Not Registered for GST

If a P&C is not registered for GST, “GST turnover” is calculated by including all of the revenue that would have included GST had the P&C been registered for GST, and making the assumption that the P&C did not elect to create input-taxed sub-entities, plus adding donations that satisfy the conditions for including donations (as described below).  Canteen revenue remains excluded from “GST turnover” because all P&Cs are assumed to treat canteen revenue as input-taxed.    

A table listing the common sources of P&C revenue and applying the above is included later.

Change in GST Registration Status

If a P&C is registered for GST in one period used for determining the reduction in its turnover and not registered for GST in the other period used for the comparison, it uses the approach applicable to its GST registration status at each separate period. For the period during which the P&C was registered for GST, the P&C’s “GST turnover” excludes the GST component from its revenue. 

Inclusion of Donations in “GST Turnover”

Donations are included in “GST turnover” of a P&C under one but not both of the following conditions:

  1. If the P&C has Deductible Gift Recipient status for a School Building Fund that has the same ABN as the P&C, any donations to the Building Fund in the relevant period are to be included in the total “GST turnover” of the P&C for that period. No other donations received by the P&C are to be included in “GST turnover”.
  1. If the above does not apply and the P&C is registered as a charity with the ACNC then any donations received by the P&C (which, by operation of the previous condition, cannot be donations to a DGR) in the relevant period are to be included in the total “GST turnover” of the P&C for that period.  

If the P&C does not satisfy either of the above conditions then no donation income it receives is to be included in the total “GST turnover” for any period.

However, while the above reflects the current JobKeeper specifications for including or excluding donations in “GST turnover” there is a strong possibility that the above specification will be changed. 

Timing of Donations Received by School on behalf of a P&C Association

Many schools collect donations requested by a P&C as part of a single payment by a parent to the school which also includes voluntary contributions requested by the school and/or subject/material charges.  In this case, where it is either impossible or impractical to determine the date on which the donations to the P&C were made by the various parents, it is reasonable to use the date(s) on which the donations were deposited in the P&C’s bank account (following their transfer by the school) as the date(s) of the donations for the purpose of determining in which period they occur for the turnover reduction test.    

A reasonable approach to determining the date(s) of donations to a P&C where the funds are never transferred to a P&C’s bank account is being investigated.  This situation could occur where a school retains the donations on behalf of a P&C until a sum is approved by the P&C for use by the school, either immediately upon collection or at a later date.  Note that P&C Federation recommends that this approach not be used and that all donations collected on behalf of a P&C should be transferred to the P&C.    

Inclusion or Exclusion in “GST Turnover” of Common P&C Revenue Items

Note: Some P&C Association canteens are registered for GST, however the majority of P&C run canteens are in-put taxed operated.

Revenue item: If the P&C is registered for GST: If the P&C is not registered for GST:
Band program feesExclude if within an input-taxed sub-entity (ie GST is not charged)
Include if not within an input-taxed sub-entity (ie, GST is charged)
Include
Before and after school care feesExclude if within an input-taxed sub-entity (ie GST is not charged)
Include if not within an input-taxed sub-entity (ie, GST is charged)
Include
Canteen salesExclude (If in-put tax operated)
Include (if GST added to products sold)
Exclude
Commission income (eg Entertainment Books)Include (but exclude if made directly to an input-taxed sub-entity with a function which legitimately includes the commission-related activity)Include
Donations and gifts (including donations and gifts to or at a fundraising event)
Refer to earlier explanationRefer to earlier explanation
Fundraising event revenue (excluding donations and gifts)Exclude if fundraising event was treated as input-taxed in line with requirements outlined earlier (ie, GST was not charged)
Include if fund-raising event was not input-taxed (ie GST was charged on ticket sales, etc)
Exclude if the fund-raising event was eligible for the fund-raising event GST concession and the P&C elected to use the concession (as described earlier)
Include if the fund-raising event was not held under the fund-raising event GST concession
Grants – Government (Federal, state or local)Include if the P&C is not a registered charity

Include if the P&C is a registered charity and has not chosen to exclude the grant income

Exclude if the P&C is a registered charity and has chosen to exclude the grant income and has notified the ATO of this exclusion
As for P&Cs registered for GST
Grants - Non-governmentInclude (but exclude if the grant did not include a GST component and was made directly to an input-taxed sub-entity with a function which legitimately includes the grant-related activity)Include
Input-taxed sub-entity revenueExcludeNot applicable: Input-taxed sub-entities can only exist if a P&C is registered for GST
Insurance claimsExclude if for loss within an input-taxed sub-entity
Include if for loss not within an input-taxed sub-entity
Include
Interest and other investment incomeExcludeExclude
Raffles or bingo (ticket sales)Include if the P&C is not a registered charity: the amount to be included is ten elevenths of the difference between total ticket sales and total monetary prizes

Exclude if the P&C is a registered charity
As for P&Cs registered for GST
P&C membership feesIncludeInclude
Uniform shop salesExclude if within an input-taxed sub-entity (ie GST is not charged)
Include if not within an input-taxed sub-entity (ie, GST is charged)
Include

Employee Eligibility

Once a P&C determines it is eligible for JobKeeper as an employer and decides to join the scheme, it must next determine which of its employees are eligible and wish to participate.  The P&C cannot discriminate between its employees.  Once the P&C enrols in JobKeeper all eligible employees who wish to participate must be included as soon as they have completed the necessary forms and sent them to the P&C. The employee eligibility rules and associated processes are described at https://www.ato.gov.au/General/JobKeeper-Payment/Employees/Eligible-employees/.

P&C employees who were employed as at 1 March 2020 and were either permanent employees (part-time or full-time) or long-term casuals (see below for further explanation) are potentially eligible. There are other requirements applying to eligibility of employees and these are further explained at the above link and also on the employee JobKeeper declaration form described and provided at https://www.ato.gov.au/Forms/JobKeeper-payment—employee-nomination-notice/.

Only One Employer Eligible for JobKeeper Payments for the One Person

An employee can only have the JobKeeper payment in respect of one employer.  If a P&C employee also has at least one other employer, the following applies:

  1. If the employee is employed on a permanent basis by one or more employers, the employee chooses which JobKeeper-enrolled permanent employer will receive the JobKeeper payment and otherwise comply with the JobKeeper scheme requirements. If none of the employee’s permanent employers are participating in the JobKeeper scheme, the employee cannot participate in the JobKeeper scheme. Any permanent employment prevents the employee participating on the basis of casual employment with a different employer.
  1. If the employee is not employed on a permanent basis by any employer but is employed on a casual basis by more than one employer and more than one of those employers are participating in the JobKeeper scheme, the employee chooses which JobKeeper-enrolled casual employer will receive the JobKeeper payment and otherwise comply with the JobKeeper scheme requirements.

Eligibility of Long-Term Casual Employees

The JobKeeper scheme provides for the inclusion of “long-term casual employees”.  The criteria for determining whether a casual employee qualifies for JobKeeper are briefly described (at the earlier employee eligibility link) as a casual employee who has been “employed on a regular and systematic basis for at least 12 months as at 1 March 2020”. This is further explained by the ATO as “a casual employee is likely to be employed on a regular and systematic basis where the employee has a recurring work schedule or a reasonable expectation of ongoing work”.

  See https://www.ato.gov.au/General/JobKeeper-Payment/In-detail/Employee-test-requirements/?page=2#Consideredalongtermcasualemployee and the examples listed there.

FAQs for Employers and Employees

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