Consultation on More Frequent Revaluations – England

On 1st July, the Government issued a consultation document on the above matter. The proposal is for the current nominal 5-year Revaluation period (subsequently extended to 7 years for the 2010 List and 6 years for the 2017 List) to be reduced to a set 3 year period.

The document can be found here.

This would appear to form part of the Chancellor’s Fundamental Review of Business Rates, currently delayed to October 2021, but the timing of this document which is flagged as an intention rather than one of a range of possibilities, suggests that the die is already cast and October will reveal “business as usual” for Rating as a taxation method. Whether or not it will still be expected to bring in approx £30bn each year is a matter for conjecture, but we all know there isn’t revenue to be given away without replacement in the current climate.

Although the tax will continue, the burden of administration for ratepayers is massively increased with the introduction in Chapter 2 of a “Duty to Inform” and a Mandatory Return of rent/lease/trade and cost information on an annual basis coupled with Civil Penalties and barring from the Appeals system for non-compliance. In any event, the Appeals system will look very different from today, as the proposal is that the currently unrestricted window for CCA will be reduced to a small 3 month period for Compiled List Challenges open to compliant ratepayers only.

Although some phasing in is possible, if implemented strictly from the start of the 2023 Revaluation, the timetable is beginning could look as follows -

1/1/2023 ( but possibly as early as Dec 2022); Ratepayers find out their new 2023 RVs and poundages and Transitional Relief provisions are announced.
March 2023; 2023/24 Rates bills arrive.
1/4/2023 to 30/6/2023; All CCA Challenges to be made. Note – a Challenge has to stand on its own merits and further detail cannot be added at Appeal unless it is new evidence which could not have been known during that window.
30/6/2023 to 31/3/2026; VOA deal with those Challenges, with a right to proceed to appeal thereafter.

Somewhere within that 1/1/2023 to 30/6/2023 period we also need to slot in the Duty to Inform and Mandatory Returns, together with any registration and agent appointment necessary on the mandatory VOA dashboard and, of course, the promised VOA transparency – but precise timing of  all these is conjecture at this stage.

We will be making our representations via our professional bodies, the RICS, RSA and IRRV, but clients are invited to make their own observations either direct or I will co-ordinate any that are sent to me. It is important that these representations contain your own views as users of the system (I refuse to refer to you as customers of that system, as you will have no choice), rather than for the Government to only receive comment from surveying organisations and companies. Comments can be made direct to Government here  and I would be very interested in seeing copies.