10427 The Retailer Autumn 2018_Final Draft Pages

• Records - It is a criminal offence under the NMW Regulations not to maintain proper records showing that the NMW has been paid in your business for at least the last three years. There is also a presumption that an employee has not been paid the NMW unless an employer can prove to the contrary and so this is an added incentive to ensuring proper records are kept. Is change on the horizon? We have submitted a formal response to Sir David’s Call for Evidence, pushing for change particularly with regard to the approach taken to salary sacrifice schemes. Unfortunately, what is clear is that change will not come quickly. In the meantime, businesses continue to be subject to HMRC audit. We would advise any retailers that have not already received an audit from HMRC to undertake their own audit to identify any potential issues so that steps can be taken to address problems sooner rather than later.

Fiona Campbell // Fiona.Campbell@squirepb.com // squirepattonboggs.com/en

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