Although HMRC are working really hard, the need for detailed guidance on the JRS is urgent. Employers are making decisions which they need to implement in the next few days - @CBItweets have estimated up to 50% will use furlough within the next 10 days, I understand. https://twitter.com/victodd/status/1245967643506548736

Quick note of uncertainties I am aware of:

1. Need for UK bank account - can agent’s account be used? Some reassurance on phone but this is high risk for agent so firm guidance needed.

2. Domestic employees - in or out? Employer is often not a “business” but employee can’t work so furlough would be appropriate.

Am personally aware of nannies being furloughed but what if they don’t qualify?

3. Overseas employer with U.K. branch - do branches qualify?

My view is that they should if they satisfy all other conditions (UK PAYE scheme and bank account) but it is not completely clear as the guidance refers to an “organisation”

4. Can directors be furloughed? Answer seems to be yes in principle (reference in self-employed scheme implies this) but hard in practice.

Some verbal assurance from HMRC that they can do “limited admin” but not yet in formal guidance

5. Can people on reduced hours be furloughed?

Two different points here. Someone on furlough must do NO WORK for employer. But someone already on reduced hours can be furloughed to zero; salary base is 28 Feb figure (this is clear in guidance)

6. Do people furloughed have to be at risk of redundancy? See discussion which started this thread - the answer so far seems to be yes, in theory, but the guidance is not yet explicit.

7. What happens if employer wants to furlough but is not sure whether they will qualify? Really hard on employees if payment withheld by employer; really hard on employer if they pay in good faith but HMRC refuse claim later.

This is the crux of why clear guidance is needed.