The deadline for annual NNDR 3 submissions will soon be upon us and it is imperative that Billing Authorities understand the implications of extended relief programmes granted as a result of the COVID pandemic alongside the usual checks and challenges that have been made. However further complicating matters is the number of applications made for Material Changes in Circumstances (MCC’s) as a result of the pandemic and it is important for Billing Authorities to have a good handle on which sectors are applying for this and the likelihood of success in these areas.
Group Pre-Challenge Reviews
Our expert valuations team here at Wilks Head & Eve have been diligently working away at this, identifying which companies are facilitating Group Pre-Challenge Reviews (GPRC’s) and becoming involved in the discussions around this early on so we can flag potential problem areas for our clients and forecast likely scenarios sooner rather than later.
Reduction in RV’s of Offices
Billing Authorities will be aware of discussions taking place between the VOA/Rating Agents, in the form of GPCR’s to look at temporary reductions in rateable value as a result of the pandemic, with the most recent under review being Offices. The Office sector accounts for around a fifth of all properties that are liable for business rates, this is a significant number and will have far-reaching implications for Billing Authorities. Towards the end of last year there was publication about a potential agreement on Offices with an estimated £481 million in potential rebates being offered according to the Altus Group. However, it’s important to note, no such agreement has been reached and at this stage discussions are yet to resume but Billing Authorities need to be factoring in the potential future losses from such agreements.
Other sectors appealing for MCC
The Office sector is just one area which has successfully appealed for a Material Change of Circumstance due to the impact of COVID but we are currently getting reports of submissions being made to the VOA for consideration in numerous other areas including Schools, Colleges, Leisure Centres, Large Airports, Car Parks and Sport stadiums such as Football and Rugby grounds. Decisions are yet to come through on these but Billing Authorities need to be aware they are in the mix and that various percentage figures are being discussed across different property types.
Complexities of interim rebates and relief
The key point to note here is the complexities that will arise if these are successfully appealed not just in factoring them in but also due to the fact there will be a specific time period for which these will apply rather than a backdate to 1 April 2017 and these will need to be individually calculated. For already overburdened finance and revenues teams dealing with the processing of grants and reliefs whilst trying to balance the books elsewhere, the drain on time and resource to administer these additional MCC’s as part of NNDR3 form completions could prove a tipping point.
If you want to find out more about how Wilks Head & Eve can assist you with your NNDR3 form submissions or forecasting please contact soneill@wilks-head.co.uk for more details.