Coronavirus measures that impact the Revenues and Rating Profession

Expanded Retail Discount 2020/21: Coronavirus Response
With Local Authorities working tirelessly to support businesses through the application of the newly expanded retail discount, we aim to support our clients as much as possible through this and have already dealt with a number of technical queries through our helpdesk. Please feel free to submit any such queries throughout this time and we will be happy to provide our views on the guidance and eligibility generally.

One of the main queries has come from clients who have more complex cases and are unsure whether properties are being wholly or mainly used for a purpose that fits within the expanded discount. Whether it is in relation to these complex cases, or more generally related to the discount or grant funding detailed below, we have detailed records that can assist in identifying the property types which should benefit and have adjusted our processes to assist Councils where required.

Accounts deadline extension
We are also working hard to ensure that these recent changes are factored into our forecasting reports. The Secretary of State recently announced that for the 2019/20 accounting period the government would be extending the period for publication of principal authority accounts to 30 September 2020.

Such a delay will give some welcome space for Councils. In any event, we have adapted our reports to take account of the changes to discounts. In summary, whilst clients will continue to need to provide for any currently undetermined losses on appeal, the cash effect of these will be impacted due to extended discount being given in 2020/21. Clients can be assured that we are adjusting our forecasting reports to include identifying any cases that are currently subject to a potential loss on appeal AND may be entitled to the extended relief – this will allow Councils (by way of a quick system check) to adjust their provision in terms of cash losses for 2020/21 where appropriate.

We would welcome feedback from clients on any other areas that we can enhance our reports to support clients through this difficult period.

The current guidance can be found here: It should be noted that the government is regularly updating its guidance and so regular checks for updates or revisions are recommended.


Grant Funding Schemes – Small Business Grant Fund (SBGF) and Retail, Hospitality and Leisure Grant (RHLG) Fund Guidance
On the 30th March 2020 the government issued ‘version 3’ of its guidance on the SBGF and RHLG, which can be found here:

The main changes are:

  • State Aid information
  • monitoring and reporting requirements
  • new annexes on State Aid, Spotlight, and post payment checks
  • clarification on eligibility of charities

Please feel free to contact us with any queries.


Council Tax and Non-Domestic Rate Appeals
The Chief Executive and Chief Operating Officer of the Valuation Tribunal Service, Antonio Masella has announced that all tribunal hearings have been postponed until 30th June 2020, at which point a review of the situation will be undertaken.

The Upper Tribunal (Lands Chamber) has announced that with the cooperation of professional and lay users and parties, and so far as it is able to do so fairly and justly, the Tribunal will determine as many applications, references and appeals as possible within the judicial and administrative resources available to it. This is likely to take the form of remote hearings and written representations where possible and fair. Although, there will obviously be an impact on the volume of cases being dealt with.


Increasing Yield – Update on property inspections
In line with the majority of the business community, we have put in place a number of contingency plans to deal with the pandemic. Our main priority is the safety and wellbeing of our employees together with our overriding social responsibility to ensure that we follow the government’s guidance to restrict movement. Obviously, it will therefore not be possible for us to continue to inspect properties during the current lockdown. Desktop work is ongoing, but we recognise that the imposition of additional rates at this time is unhelpful. In any event, our fully e-BAR compliant reporting generally requires more information than can be provided solely from desktop activity and as such we will pause the reporting of cases until such time as it is both possible and more appropriate.


COVID-19 – Material Change of Circumstances
We have recently been made aware that some ratepayers across different classes of property are asking agents whether the current circumstances of COVID-19 warrants a Material Change of Circumstances challenge to Rateable Value. We are of the view that the legal basis for such a claim could probably be made in certain instances but the value effect of any change on property if any is still an unknown and if it exists will not be geographically or by use uniform in nature. We have been working with the IRRV to encourage those members advising clients to carefully consider whether a realistic case can be made in individual circumstances and certainly to avoid any blanket approach. We take the view that the Rating profession should act responsibly in advising clients in these circumstances without unnecessarily exacerbating workloads on the VOA and Billing Authorities where there is little or no prospect of a successful MCC in these difficult and unprecedented times. Whilst we are not currently aware of the VOA’s approach to this, due to the delays in tribunal proceedings, it is unlikely that such matters will be resolved in the near future.


Council owned properties – potential reliefs, exemptions, allowances
As you will know, the expanded reliefs cannot be applied to properties where Councils and preceptors are the ratepayer. However, due to the unprecedented circumstances, it is possible that many of these properties are entitled to other reliefs, exemptions or temporary allowances which could include looking at potential material changes through Check and Challenge resulting in reductions in rateable value/liability. We would be able to protect the interests of our clients, whilst ensuring we do not create an additional burden for revenues teams by undertaking this work on our clients’ behalf. If this is something that you would be interested in us reviewing for you then please get in contact with one of the team and we would be happy to discuss this further with you.


Thanks and Support
We recognise the important work the public sector has been undertaking to assist the country through this difficult time. There is no doubt that the economic provisions put in place by government and primarily delivered by Local Authorities are crucial. We just wanted to add our thanks to you for your hard work and commitment and hope that you are all able to stay safe and well and continue to follow the government guidance during these unprecedented times. We remain happy to support you as much as we are able through this period. Direct contact details for our key personnel are detailed below:

Alistair Townsend: Director Public Sector Revenues, M: 07903 314301 E:
Steph O’Neill: Partner, M: 07900 575998 E:
Roger Messenger: Senior Partner, M: 07836 203002 E: