The position of Chartered Accountants Ireland is that there is no better safeguard to our economic recovery and success than the effective containment of COVID-19. Nevertheless, given the scale of the recommendation from NPHET were it to be implemented, we must emphasise the colossal disruption to Irish business, already managing its way to a partial recovery from the first lockdown in March, April and May of this year.

It is clear to us that if a change in restrictions to Level 5 is to be introduced, many businesses particularly those in the SME sector will suffer greatly, and many lower paid jobs in particular will be put under threat. This is based on the experience of our 19,000 members employed in industry and practice in this country.

Accordingly, should the Government decide to revert to Level 5 restrictions, we believe at a minimum that the following financial and expenditure measures are required with immediate effect:

1. Requesting Revenue for the reinstatement of the Temporary Wage Subsidy Scheme to the April levels. We believe this will cost, by reference to the cost of the Temporary Wage Support Subsidy in May, somewhere in the order of €700 million. It is necessary to reinstate the Temporary Wage Subsidy Scheme because the method of support delivery is immediate and therefore superior to the Employee Wage Subsidy Scheme currently in process. The Employee Wage Subsidy Scheme was designed to operate against a background where many of the strictest public health restrictions on the economy have been eased.
2. Requesting Revenue for the immediate warehousing of all fiduciary tax obligations for the duration of the Level 5 move. Again, by reference to earlier experience, we anticipate this should cost in the order of €800 million for the month of October.
3. The suspension of reporting and filing obligations to the various agencies governed under your remit and by the Department of Business, Enterprise and Innovation. Scarce compliance resources, already challenged by the coronavirus response and Brexit planning, must be diverted to helping businesses make financial plans for the duration of the Level 5 restriction.
4. The introduction of a premises maintenance grant. As we approach the winter months, and unlike the last lockdown period, underutilised or unused business premises closed or partially closed because of the restrictions will deteriorate quickly in inclement weather. We recommend that an immediate grant of the 15% of the rates payable annually on each premises be provided to assist in ensuring that, when the restrictions ease, businesses can reopen as quickly as possible. By reference to the cost of the rates forbearance measures earlier this year, such a grant will cost in the order of €150 million.

Ministers, we fully appreciate the magnitude and difficulty of the decisions which must be taken this week. We are not in a position to comment on the appropriateness of the NPHET recommendations and are not doing so. However please take this letter as a suggestion of immediate practical steps which need to be taken, were Level 5 to be reimposed, for Irish business needing additional support.

We are happy to carry out any research or provide any information further that can help in the decision-making and the business support process in the coming weeks. We wish you and your cabinet colleagues every success in this difficult time.