The impact of Covid-19 on the global insurance industry – United Kingdom

United Kingdom

General questions

Yes/ No/ N/A

Additional comments, if any.

1

Does the country that you are reporting on follow common law jurisprudence?

Yes

2

If the answer to the above question is no, does the country you are reporting on follow a civil code? Please describe the judicial system in short.

N/A

3

Please provide a brief description of the legal framework applicable to insurance coverage disputes in the country you are reporting on. In so doing, please consider the following questions:

English insurance law is a mixture of common law (drawn from cases before the courts) and statute. Many of the principles developed during early insurance disputes, including the duty of ‘utmost good faith’ were codified in the Marine Insurance Act 1906 (the 1906 Act), which continues to influence insurance law in England & Wales. Although the 1906 Act specifically governs marine insurance, many of its sections and principles are also applicable to non-marine insurance contracts and it was the most significant statute in English insurance law until the Insurance Act 2015 (the 2015 Act) came into force on 12 August 2016. The 2015 Act is currently the main legislation relevant to insurance coverage disputes.

4

Does the insured bear the burden of establishing coverage of a claim, or does the insurer bear the burden of establishing no coverage? Please give a short description of the legal basis in your country.

The insured is required to prove that a loss has occurred, and that the loss was proximately caused by an insured peril. Once this has been done, the burden shifts to the insurers to make out their defence, for example, that the loss resulted from the insured’s own deliberate act or an excluded peril.

5

Are coverage provisions in policies interpreted broadly or is there a presumption in favour of coverage? Please give a short description of the legal basis in your country.

The relevant case law demonstrates that the following principles are relevant to insurance policies:

• the insured must prove that the loss or damage was caused by the operation of the general risk insured against;
• if the general risk is qualified by the exception of specific risks, which but for the exception would fall within the general risk, and some part of the general risks is left unqualified, the burden is on the insurer to prove facts which bring the case within the exception relied on;
• whether a qualification of the general risk is in the nature of an exception or a qualification of the whole risk is in every case a question of construction of the policy as a whole; and
• in construing a policy, it must be borne in mind that a general risk with exceptions can generally be turned by an alteration of phraseology into a general risk with a qualification covering its whole scope.

6

Are exclusions interpreted narrowly or is there a presumption against finding that an exclusion to coverage applies? Please give a short description of the legal basis in your country.

The insurer bears the burden of proving that the exclusion applies as a matter of fact. It should also be noted that there are judicial decisions where the court has applied the principle of contra proferentum to exclusion clauses (ie, the clause is construed against the party which drafted it).

7

Are there universally accepted definitions for:

• event
• occurrence
• damage
• cause
• originating cause
• natural peril
• force majeure
• loss
• consequential loss

If the answer is yes, please give a short description of each definition and the legal basis for that definition (ie, a rule of law, case law etc).

event/occurrence

In Axa Reinsurance (UK) Plc v Field [1996] 1 W L R 1026, Lord Mustill commented that ‘in ordinary speech, an event is something which happens at a particular time, at a particular place and in a particular way’. This terminology is generally adopted: something specific must have happened. An event is what has happened as opposed to the reason (underlying cause) for what has happened. An event or occurrence is, accordingly, to be distinguished from a general state of affairs, such as a propensity to act negligently or a war, as there is no loss arising from these sources unless and until something specific has happened.

damage

Damage in an insurance context is often referred to as an adverse change in physical condition. There are three elements to this: (1) damage is concerned with the physical condition of the subject matter; (2) damage requires a change to that physical condition occurring within the period of cover; and (3) the change must, obviously, be for the worse – it must impair the use or worth of the item.

cause/originating cause

The term ‘originating cause’, by way of contrast to ‘event’ or ‘occurrence’, is concerned with the underlying reason for a series of losses rather than the losses themselves. As was said by Lord Mustill in Axa Re v Field [supra]: ‘A cause to my mind is something altogether less constricted. It can be a continuing state of affairs; it can be the absence of something happening. Equally, the word “originating” was in my view consciously chosen to open up the widest possible search for a unifying factor in the history of the losses which it is sought to aggregate. To my mind the one expression [originating cause] has a much wider connotation than the other [event].’

natural peril

We are not aware of any universally accepted definition of Natural peril under English law.

force majeure

The term force majeure – the literal meaning of which is ‘superior force’ – has its origins in French civil law. However, under English common law there is no doctrine of force majeure. Instead, the term is a convenient ‘label’ used to refer to clauses which relieve a party from performance of its contractual obligations where that performance is affected by events outside its control, such as natural disasters or war.

loss

The word ‘loss’ does not have a fixed meaning, and much will depend on its context.

consequential loss

Consequential loss most commonly is manifested in the form of loss of profit, and in most cases the amount of consequential loss suffered by the insured following the occurrence of an insured peril is a matter of speculation. The general rule is that insurance covers physical damage resulting from an insured peril, and that consequential loss is not insured unless the policy specifically so provides. Loss of profits flowing from the interruption of business activities, that is, business interruption insurance, is a standard form of cover.

Loss causation

Yes/No/ N/A

Additional comments, if any.

8

Did the country that you are reporting about issue lockdown, stay-at-home or no-travel restrictions in response to Covid-19?

Yes

9

If the answer to the question above is yes, were such orders issued nationally, by state/region or by local city/town. Please give a short description of the issuing authority and the orders issued.

The first national lockdown in March 2020 was ordered by the government and enshrined in Law with the Health Protection (Coronavirus, Restrictions) (England) Regulations, dated 26 March 2020. Schools were closed to most students. Individuals were not permitted to leave their homes without a ‘reasonable excuse’. Reasonable excuses were (for example) to access healthcare, to go to work, if you could not work from home and to obtain essential supplies. Non-essential retail and leisure facilities were required to close.

In the summer of 2020, the government adopted a tiered approach based on infection rates within local areas. Those within Tiers 1 and 2 had fewer restrictions (most businesses were permitted to open for example). Those within Tiers 3 and 4 had more restrictions (for example, some non-essential businesses were required to close). An additional Tier 5 was introduced in January 2021 and this imposed restrictions that were as extensive as the first national lockdown with the exception that schools could remain open.

In the summer and autumn of 2020, the government also imposed local lockdowns in areas where infection rates spiked. Leicester, Liverpool and Manchester were locations in which local lockdowns were imposed.

The tiered approach remained in operation until January 2021, when the government placed the whole of England in Tier 5, effectively imposing a second national lockdown. Those restrictions were gradually lifted in the months that followed.

In the autumn of 2020, the government implemented ‘Plan A’ which saw most restrictions lifted and a focus on rolling out Covid-19 vaccinations.

In December 2021 the government announced the implementation of ‘Plan B’ due to the rapid spread of the Omicron variant. In Plan B: face masks were compulsory in most public venues and those that could, were advised to work from home. All Plan B measures came to an end on 26 January 2022.

10

If the answer to the above question is yes, were the lockdown, stay-at-home or no-travel restrictions mandatory or recommended?

The stay-at-home orders were mandatory.

11

If the country that you are reporting about did issue lockdown, stay-at-home or no-travel restrictions, were those orders suspended or revoked at any point in time? If the answer is yes, please give a short description of the timeline.

Yes

Please see the response to Question 9, which provides a brief timeline of events, summarising the key orders issued.

12

If the answer to the above question is yes, were subsequent lockdown, stay-at-home or no-travel restrictions issued at any point in time? Please give a short description of the timeline.

Please see the response to Question 9, which provides a brief timeline of events, summarising the key orders issued.

13

Has the country that you are reporting about issued judicial opinions or guidance analysing whether Covid-19 is a ‘cause’ of insured loss?

Yes

14

Has the highest court in the country you are reporting about issued judicial opinions or guidance analysing whether Covid-19 is a ‘cause’ of insured loss? If the answer is yes, please give a short description of the conclusions in the judicial opinions or guidance.

Yes

In January 2021, the UK Supreme Court published its judgment in the Financial Conduct Authority (FCA) business interruption insurance test case, FCA and Others v Arch Insurance (UK) Limited and Others [2021] (the Test Case). In the Test Case, the Supreme Court considered 21 sample policy wordings for non-damage business interruption insurance extensions and decided for each wording whether cover was confirmed in principle. In summary, the Supreme Court decided that cover would be available in principle for certain ‘disease’, ‘prevention of access’ and ‘hybrid’ clauses subject to certain criteria being met. In some cases, the criteria would not be met and cover would not be available in principle. The outcome depends on the particular wording of the policy in question.

15

If the answer to the question above is yes, did the highest court in the country you are reporting about determine that losses related to Covid-19 were ‘caused’ by the virus? Please give a short description of the conclusions in the judicial opinions or guidance.

No

The Supreme Court did not decide that losses relating to Covid-19 were ‘caused’ by the virus. However, the Supreme Court decided that when there are concurrent causes, one that is insured and another or several others that are not insured, causation will be satisfied so long as the concurrent causes have ‘equal efficacy or equal weight.’ For example, in respect of the disease clauses, the Supreme Court decided that it would be enough for a policyholder to show that its business interruption was a result of the Government Action which was taken in response to all cases of Covid-­19, as long as they could evidence at least one case of Covid-19 prior to such action within the geographical limit.

16

If the answer to the above question is no, did the highest court in the country you are reporting about determine that losses related to Covid-19 were ‘caused’ by government lockdown or stay-at-home orders? Please give a short description of the conclusions in the judicial opinions or guidance.

Yes

See the response to Question 15 above.

17

Has the country that you are reporting about issued judicial opinions or guidance analysing whether Covid-19 is an ‘originating cause’ of insured loss? If the answer is yes, please give a short description of the conclusions in the judicial opinions or guidance.

Yes

Yes, with reference to particular types of policy wordings and clauses.

The Supreme Court concluded in the Test Case that the prevention of access/hybrid wordings indemnify the policyholder against the risk of all the elements of the insured peril acting in causal combination to cause business interruption loss. It did so regardless of whether the loss was concurrently caused by other (uninsured but non-excluded) consequences of the Covid-19 pandemic, which was the underlying or originating cause of the insured peril.

In respect of trends clauses, the Supreme Court held that these clauses should not be construed so as to take away cover provided by the insuring clauses and that the trends and circumstances for which the clauses require adjustments to be made do not include circumstances arising out of the same underlying or originating cause of the insured peril, that is, in this case Covid-19.

18

If the highest court in the country you are reporting about has not issued judicial opinions or guidance analysing whether Covid-19 is a ‘cause’ of insured loss, have other courts in the country issued such opinions?

N/A

19

If the answer to the above question is yes, have courts in the country you are reporting on interpreted this issue consistently? In other words, is there uniformity in jurisprudence as to whether Covid-19 is a ‘cause’ of insured loss? Please give a short description of the conclusions in the judicial opinions or guidance.

N/A

20

If the answer to the above question is yes, do courts in the country you are reporting about hold that losses related to Covid-19 were ‘caused’ by the virus? Please give a short description of the conclusions in the judicial opinions or guidance.

N/A

21

If the answer to the above question is no, do courts in the country you are reporting about determine that losses related to Covid-19 were ‘caused’ by government lockdown or stay-at-home orders? Please give a short description of the conclusions in the judicial opinions or guidance.

N/A

22

Has the highest court in the country you are reporting about issued judicial opinions or guidance analysing whether Covid-19 is an ‘originating cause’ of insured loss?

Yes

Please see the response provided to Question 17.

23

If the highest court in the country you are reporting about has not issued judicial opinions or guidance analysing whether Covid-19 is an ‘originating cause’ of insured loss, have other courts in the country issued such opinions? If yes, please give a short description of the conclusions in such judicial opinions or guidance.

No

24

Has the country that you are reporting about issued judicial opinions or guidance analysing whether Covid-19 is a covered ‘event’?

Yes

The Test Case considered wordings which referred to an ‘event’. It found that an ‘event’ is something which happens at a particular time, at a particular place, in a particular way. Each case of Covid-19 was a separate occurrence of the disease, or a separate event. If the other elements of the insuring clause are satisfied and if the insured event is a concurrent cause of the losses incurred, then there will be cover in principle in respect of the policy wordings that were considered in the Test Case.

25

Has the highest court in the country you are reporting about issued judicial opinions or guidance analysing whether Covid-19 is a covered ‘event’? Please give a short description of the conclusions in the judicial opinions or guidance.

Yes

Please see the response to Question 24.

26

If the answer to the question above is yes, did the highest court in the country you are reporting about determine that losses related to Covid-19 were covered ‘events’? Please give a short description of the conclusions in the judicial opinions or guidance.

No

Please see the response to Question 24 above. All elements of the insuring clause must be satisfied for there to be cover in principle. Covid-19 of itself was not held to be an insured event. However, if there was an insured event and it was a concurrent cause of the losses suffered, cover would be available to the policyholder in principle.

27

If the highest court in the country you are reporting about has not issued judicial opinions or guidance analysing whether Covid-19 is a covered ‘event’, have other courts in the country issued such opinions?

N/A

28

If the answer to the above question is yes, have courts in the country you are reporting on interpreted this issue consistently? In other words, is there uniformity in jurisprudence as to whether Covid-19 is a covered ‘event’? Please give a short description of the conclusions in such judicial opinions or guidance.

N/A

29

If the answer to the above question is yes, do courts in the country you are reporting about hold that losses related to Covid-19 are covered ‘events’? Please give a short description of the conclusions in the judicial opinions or guidance.

N/A

30

If the answer to any of the above questions regarding your country’s jurisprudence was no, please comment on whether there are any other official sources or authorities that have issued contributions to the interpretation of Covid-19 in the context of loss causation.

N/A

Aggregation of claims

Yes/ No/ N/A

Additional comments, if any.

31

Does the country you are reporting on permit aggregation of claims arising out of a single originating cause? Please give a short description of the legal basis.

Yes

In Axa Re v Field [Supra], the House of Lords held that an event is something which happens at a particular time, at a particular place, and in a particular way. A cause is something less constricted. It can be a continuing state of affairs; or the absence of something happening. The word ‘originating’ opens up the widest possible search for a unifying factor and has a much wider connotation.

An aggregation on the basis of an ‘originating cause’ is wider than event or occurrence-based wording.

32

Does the country you are reporting on permit aggregation of claims arising out of a single cause? Please give a short description of the legal basis.

Yes

The relevant case law does not draw a distinction between the phrase ‘originating cause’ and the word ‘cause’, as both are regarded as giving a wider basis for aggregation than ‘event’.

Therefore, please also see the response provided for Question 31.

33

Does the country you are reporting on permit aggregation of claims arising out of a single event? Please give a short description of the legal basis.

Yes

The most common type of aggregation clause is one that groups losses or claims by reference to a single ‘event’ or ‘occurrence’. These terms are usually interchangeable.

Accordingly, in Caudle v Sharp [1995] LRLR 433, the Court of Appeal observed that while the Second World War, the Hundred Years’ War or the Ice Age might in common parlance be described as an ‘event’, they cannot be treated as such for the purpose of an aggregation clause in the insurance or reinsurance context, because an ‘event’ requires ‘some causative element’ and a ‘lack of remoteness’ depending on the circumstances of the particular case. Evans LJ said that there are three requirements of a relevant ‘event’:

• there was a common factor which can properly be described as an event;
• that event satisfied the test of causation giving rise to the loss or claim; and
• the event was not too remote for the purposes of the aggregation clause.

The ‘event’ or ‘occurrence’ in question need not be the peril insured against. Nor need it be the proximate cause of the loss; rather, ‘the causative link has to be a significant rather than a weak one’.

34

Does the country you are reporting on use an accepted test for determining whether claims can be aggregated? For example, does the country you are reporting on apply to four unities test to determine whether aggregation is appropriate? Please give a short description of the legal basis.

Yes

In determining whether losses arise from a single event, the court will often apply the concept of ‘unities’, first introduced by Michael Kerr QC (later Kerr LJ) in the Dawson’s Field Award (29 March 1972) and adopted by Rix J in Kuwait Airways Corp v Kuwait Insurance Co SAK (No 1) [1996] 1 Lloyd’s Rep 664. The unities are those of cause, locality, time and the intention or motive of any human agents.

While the unities are a useful guide, they are not to be treated as an inflexible test. The court will approach the matter from the perspective of the insured and scrutinise the circumstances ‘to see whether they involve such a degree of unity as to justify their being described as, or arising out of, one occurrence’. This involves an ‘exercise of judgment’ to be conducted ‘globally and intuitively’. (Scott v Copenhagen Reinsurance Co (UK) Ltd [2003] EWCA Civ 688).

35

Have courts in the country you are reporting on issued jurisprudence concerning whether insureds can aggregate claims arising out of Covid-19? Please give a short description of the legal basis.

No

Aggregation was not in the scope of issues that has been considered by the court in the Test Case.

36

Has the highest court in the country you are reporting about issued judicial opinions or guidance concerning whether insureds can aggregate claims arising out of Covid-19? Please give a short description of the conclusions in such judicial opinions or guidance.

No

Please see the response to Question 35.

37

If the answer to the question above is yes, did the highest court in the country you are reporting about determine whether insureds can aggregate claims arising out of Covid-19? Please give a short description of the conclusions in such judicial opinions or guidance.

N/A

38

If the highest court in the country you are reporting on has not issued such jurisprudence, have other courts in the country you are reporting on interpreted this issue consistently? In other words, is there uniformity in jurisprudence as to whether insureds may aggregate claims arising out of Covid-19? Please give a short description of the conclusions in such judicial opinions or guidance.

No

Please see the response to Question 35.

39

If the answer to the above question is yes, do courts in the country you are reporting about permit insureds to aggregate claims arising out of Covid-19? Please give a short description of the conclusions in such judicial opinions or guidance.

N/A

40

Do the courts in the country you are reporting on permit an insured to aggregate claims related to multiple properties or business locations arising out of Covid-19? Please give a short description of the conclusions in such judicial opinions or guidance.

N/A

Please see the response provided to Question 35.

41

Do the courts in the country you are reporting on permit an insured to aggregate claims related to multiple lockdown or stay-at-home orders arising out of Covid-19? Please give a short description of the conclusions in such judicial opinions or guidance.

N/A

Please see the response provided to Question 35.

42

Have courts in the country you are reporting on issued jurisprudence concerning whether cedents can aggregate claims arising out of Covid-19? Please give a short description of the legal basis.

No

43

If the answer to the above question is yes, have courts in the country you are reporting on interpreted this issue consistently? In other words, is there uniformity in jurisprudence as to whether cedents may aggregate claims arising out of Covid-19? Please give a short description of the conclusions in such judicial opinions or guidance.

N/A

44

If the answer to the above question is yes, do courts in the country you are reporting about permit cedents to aggregate claims arising out of Covid-19? Please give a short description of the conclusions in such judicial opinions or guidance.

N/A

45

If the answer to any of the above questions regarding your country’s jurisprudence was no, please comment on whether there are any other official sources or authorities that have issued contributions to the interpretation of Covid-19 and aggregating claims.

No

Property damage

Yes/ No/ N/A

Additional comments, if any.

46

Have courts in the country you are reporting on issued jurisprudence concerning whether losses arising from Covid-19 qualify as property damage losses? Please give a short description of the legal basis.

Yes

This was not addressed in the Test Case. However, in the case of TKC London Limited v Allianz Insurance Plc [2020] EWHC 2710 (Comm) (15 October 2020) the Court confirmed that when policies define loss by reference to damage to property, the insuring clauses will not be triggered by the temporary loss of the use of a business premises due Covid-19. The established position is that policies which provide cover for physical damage (ie, traditional damage based bodily injury (BI) cover) will not provide cover for losses resulting from the occurrence of Covid-19 or the measures introduced by the government to prevent the spread of Covid-19.

47

Has the highest court in the country you are reporting about issued judicial opinions or guidance concerning whether losses arising from Covid-19 qualify as property damage losses? Please give a short description of the conclusions in such judicial opinions or guidance.

No

The issue has not been considered by the Supreme Court in the Test Case but the decision from the lower court has not been appealed.

48

If the answer to the question above is yes, did the highest court in the country you are reporting about determine whether losses arising from Covid-19 qualify as property damage losses? Please give a short description of the conclusions in such judicial opinions or guidance.

N/A

49

If the highest court in the country you are reporting on has not issued such jurisprudence, have other courts in the country you are reporting on interpreted this issue consistently? In other words, is there uniformity in jurisprudence as to whether losses arising from Covid-19 constitute property damage? Please give a short description of the conclusions in such judicial opinions or guidance.

Yes

Please see the response to Question 46 above.

50

If the answer to the above question is yes, do courts in the country you are reporting about permit insureds to aggregate claims arising out of Covid-19? Please give a short description of the conclusions in such judicial opinions or guidance.

No

Aggregation was not in the scope of issues that has been considered by the court in the Test Case.

51

If the answer to any of the above questions regarding your country’s jurisprudence was no, please comment on whether there are any other official sources or authorities that have issued contributions to the interpretation of Covid-19 and property damage.

No

Exclusions

Yes/ No/ N/A

Additional comments, if any.

52

Has Covid-19 been deemed a ‘natural peril’ in the country you are reporting on? Please give a short description of the legal basis and relevant jurisprudence.

No

53

Has Covid-19 been deemed force majeure in the country you are reporting on? Please give a short description of the legal basis and relevant jurisprudence.

No

54

Is Covid-19 acknowledged as a notifiable disease in the country you are reporting on? Please give a short description of the legal basis and relevant jurisprudence.

Yes

On 5 March 2020, the UK Government added Covid-19 to the list of notifiable diseases by adding it to the list contained within the Health Protection (Notification) Regulations 2010.

55

Is it common for insurance policies issued in the country you are reporting on to include a pandemic or virus exclusion? Please give a short description of the legal basis and common insurance practice.

No

Although it was not necessarily ‘common’ for insurance policies to include a pandemic or virus exclusion, some policies did exclude cover under certain non-damage BI insurance extensions for losses relating to infectious diseases.

Since March 2020, many insurers have added endorsements to renewal policies which excludes cover for losses arising out of or connected to Covid-19 or the measures introduced by the government to prevent its spread.

56

Have any courts in the country you are reporting on determined that a pandemic or virus exclusion is void as against public policy in the context of Covid-19? Please give a short description of the legal basis and relevant jurisprudence.

No

57

Have any courts in the country you are reporting on otherwise determined that a pandemic or virus exclusion is unenforceable in response to Covid-19? Please give a short description of the legal basis and relevant jurisprudence.

No

58

If the answer to any of the above questions regarding your country’s jurisprudence was no, please comment on whether there are any other official sources or authorities that have issued contributions to the interpretation of Covid-19 in the context of exclusions.

The Financial Ombudsman Service (the FOS) has jurisdiction to hear certain types of complaints made by consumers or small businesses. The FOS has looked at complaints relating to the exclusion of cover for losses caused by an infectious disease in some non-damage business interruption insurance extensions. It has not upheld those complaints on the basis that the exclusions are fair and reasonable and should be applied to limit cover.

Regulatory oversight

Yes/ No/ N/A

Additional comments, if any.

59

Have insurance regulators in the country you are reporting on issued directives concerning coverage for claims arising out of Covid-19? Please describe the regulations that have been implemented.

No

Whilst the FCA has not issued any directives concerning coverage for claims arising out of Covid-19:

• It did intimate and pursue the Test Case to obtain judicial opinion on whether certain policy wordings will provide cover in principle for losses caused by the occurrence of Covid-19, or by government measures to reduce the spread of Covid-19.
• It has published ‘Dear [Chief Executive Officer]’ letters to insurers, setting out how it expects insurers to review and progress claims.
• It has published guidance to insurers, asking them to reassess policies to check that they remain suitable in light of the issues surrounding Covid-19 and to adopt a reasonable and sensible approach when assessing any terms in the policy which an insured may not be able to comply with due to the circumstances surrounding Covid-19.
• It has published guidance notes on issues such as how to prove the prevalence of Covid-19 within a certain geographical limit to assist policyholder and insurers when assessing claims.
• It requires insurers to provide monthly data on the number of business interruption claims made, the number of claims that are settled and the payments that have been made. It is publishing some of that data on its website and updating it on a monthly basis.

60

Are regulators requiring or encouraging insurers to provide grace periods to insureds to make payments on premiums? If yes, please give a short description of the legal basis and relevant guidance.

No

Whilst the FCA has not specifically addressed this issue, it has in its guidance, encouraged insurers to adopt a reasonable and pragmatic approach towards policyholders generally due to the circumstances caused by Covid-19. This may (in certain circumstances) include arrangements regarding the payment of premiums.

Government action

Yes/ No/ N/A

Additional comments, if any.

61

Has the government in the country you are reporting on implemented relief measures for losses sustained as a result of Covid-19?

Yes

62

If the answer to the above question is yes, are the relief measures available to both individuals and businesses?

Yes

63

Briefly describe the types of relief measures available to individuals and businesses.

• direct grants for hospitality and leisure businesses;
• local authority discretionary grants for other businesses;
• theatre and museum funding;
• statutory sick pay funding for small- and medium-sized enterprises (SMEs);
• government-backed loans to businesses;
• business rates reliefs;
• direct business grants;
• Self-Employed Income Support Scheme (SEISS);
• VAT deferral;
• tax – Improved Time To Pay arrangements;
• paying Statutory Sick Pay (SSP);
• Coronavirus Job Retention Scheme;
• potential tax issues arising from international travel restrictions;
• package for Innovative Businesses: Future Fund and £750m research and development commitment;
• mortgage payment holiday; and
• apprenticeship grants.