The alternative decline in turnover test rules for the JobKeeper payment scheme have been released by the ATO

  • The JobKeeper legislation now contains an ‘alternative test’

  • The Commissioner may now determine a different approach for proving the decline in turnover for a class of entities

  • Extension announced for enrolment deadline – now the 31st May 2020

On the 23rd April 2020, the Commissioner of Taxation issued a legislative instrument that provides 7 alternative tests for meeting the decline in turnover test under the JobKeeper scheme.  There are now 7 alternative tests to the basic test  with the alternative tests kicking in if an entity cannot satisfy the basic decline in turnover test.

An alternative test may now apply in these circumstances

  1. start-up businesses
  2. businesses that have experienced a disposal acquisition
  3. businesses that have experienced a restructure
  4. an entity that actually had a substantial increase in turnover before COVID-19 struck
  5. an entity affected by drought or some other type of natural disaster
  6. an entity with irregular turnover
  7. a sole trader or small partnership impacted by sickness, injury or leave.


Applying an alternative test

If an alternative test applies, you can apply the decline in turnover test by comparing the relevant test period turnover (March to September 2020) with an alternative comparison period turnover.   

For example if the entity commenced business after the comparison period in 2019, the alternative test allows the entity to use an average turnover since the entity commenced business and prior to 1 March 2020.

If you fall into more than one of the circumstances listed above, you can choose which alternative decline in turnover test to apply. You only need to satisfy one of the tests (it does not matter if you do not satisfy one of the other tests that applies to you).  While the concepts are relatively simple, there is some complexity in the calculations to determine the alternative comparison period turnover.


Before you access the JobKeeper scheme as an employer, you should undertake a cost benefit analysis taking into account some of the matters raised in this article.

You need to consider how your business’ cash flow will be impacted in order to access JobKeeper.

You also want to make sure you do not create unforeseen workplace disputes in trying to access the JobKeeper payments.

Contact us

Enrolments for the scheme close on the 31st May 2020 so get in contact with your local Bentleys tax advisor if you need assistance with which of these tests applies to you and your business.

We, at Bentleys, are doing everything we can to help businesses come out of this challenging time in good shape.

We will continue to update our COVID-19 resource hub with important developments, so please return soon.

Disclaimer: This information is general in nature and should not be relied on as advice. It does not take into account the objectives, financial situation or needs of any particular person. You need to consider your financial situation and needs and seek professional advice before making any decisions based on this information.

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