Chartered Accountants Australia and New Zealand, Corporate Tax Association, CPA Australia, Institute of Public Accountants, Law Council of Australia and The Tax Institute are the external members of the NTLG. These organisations, with the exception of the Corporate Tax Association and the Law Council of Australia, (hereafter referred to as the Joint Bodies) have lodged a submission to The Treasury on 27 November 2020 regarding the JobMaker Hiring Credit Exposure Draft Rules.

Overall, the Joint Bodies supported the JobMaker Hiring Credit (JobMaker) measure under the Exposure Draft Coronavirus Economic Response Package (Payments and Benefits) Amendment Rules (No. 9) 2020 and the Exposure Draft Explanatory Material.

However, the Joint Bodies raised a number of issues for Treasury’s consideration:

1. Complexity and uncertainty – there is a high degree of uncertainty for employers, not only in relation to whether they may be entitled to JobMaker, but also as to the extent to which they are so entitled. This uncertainty stems from the complexities of the various calculations that must be undertaken, particularly the ‘headcount increase’ requirement and events outside the control of the employer. This will also be problematic for advisers responding to clients who wish to make hiring decisions on the basis that they will receive a hiring credit.  
2. Technical clarifications – a table recommending a number of technical corrections to the Exposure Draft.  Consolidated group, carrying on a business, and restructuring issues were also raised.
3. Post-implementation review - a post-implementation review should be undertaken around six months after the JobMaker program has come into effect to consider the impact and effectiveness of the program. It should involve public disclosure of the number of people hired as a result of this program (similar to Treasury’s three-month review of the JobKeeper payment).