04/03/2011/ 1326

Business Rates Review (England)

This document, issued by the Treasury under the Conservative and Liberal Democrat coalition government, sets out the terms of reference for the government’s review and provides further information on the review’s aims and core themes. The government welcomed responses from a wide range of interested stakeholder to the questions and requests for evidence included in this paper by 12 June 2015. The review will report its findings by Budget 2016.

IRRV Response BRates Review June 2015.pdf

Call for Written Evidence by the Commission on Local Tax Reform (Scotland)

The Call for Written Evidence by the Commission asked for views on the future of local taxation in Scotland.

It will use the information to develop its work and explore new ideas  The call for written evidence closed on 22 June 2015. All of the responses will be independently read and analysed and the Commission will publish a report setting out this analysis later in the summer.

Call for written evidence

The IRRV welcome Business Rates Review by Treasury

THe IRRV has welcome the discussion paper launched by the Treasury on 16th  March 2015

Read Response

Business rates review: terms of reference and discussion paper

Extent: England
Published 16th March 2015
Closing Date: 12th June 2015


This document sets out the terms of reference for the government’s review and provides further information on the review’s aims and core themes. The government welcomes responses from a wide range of interested stakeholder to the questions and requests for evidence included in this paper by 12 June 2015. The review will report its findings by Budget 2016.

Exemptions to the Council Tax premium on Second Homes in Wales

Extent: Wales
Published 13th March 2015
Closing Date: 13th June 2015


This consultation seeks views on proposals for Welsh Ministers to exempt certain categories of dwelling from the additional Council Tax on Second Homes in Wales.

Exemptions to the Council Tax Premium on Long-Term Empty Homes in Wales

Extent: Wales
Published 13th March 2015
Closing Date: 13th June 2015


This consultation seeks views on proposals for Welsh Ministers to exempt certain categories of dwelling from the additional Council Tax on Long-Term Empty Homes in Wales.


Administration of Business Rates in England: Interim Findings

At Autumn Statement 2013, the government announced it would open up a discussion with businesses and local authorities about long-term administrative reform to business rates in England after 2017. This paper summarises the government’s interim findings on the administrative reform of business rates and sets out how the government proposes to respond to businesses’ calls for clearer billing, better sharing of information and a more efficient appeals system.  The Institute responded to this interim findings document. 

LINK to original consultation paper:

IRRV Response


Business rates avoidance

The government is committed to dealing with avoidance in the tax system. At Autumn Statement 2014, the government announced it would open up a discussion to:

  • better understand the type and scale of business rates avoidance in England
  • find ways to tackle business rates avoidance so that all ratepayers pay the business rates that they should pay

This document built on the work undertaken by the government’s anti-avoidance working group and requested responses from interested parties to further inform the government as to the types and scale of avoidance, as well as ideas around potential solutions.  The IRRV responded to this consultation paper.

LINK to original consultation document:

IRRV Response


Council Tax and business rates: powers of entry

Following its review of the powers of entry the DCLG identified two powers operated by the Valuation Office Agency which it proposed to amend.  These powers of entry are operated by the Valuation Office Agency’s listing officers and valuation officers as part of their duty to assess domestic and non-domestic properties for banding purposes and rateable values respectively.  The IRRV responded to this consultation.

LINK to original document: Response BRates Avoidance 280215.pdf

IRRV Response


Scottish NDR Valuation Appeals System

On 27 November 2012, the Scottish Government published its consultation, Supporting Business – Promoting Growth, on reforms to the business rates system. An independent analysis of all responses was published on 4 September 2013, along with the Scottish Government response.

The analysis found that many respondents felt the appeals system was cumbersome, time-consuming and costly for ratepayers, who often have limited understanding of the system and need to pay professional advisors to assist with an appeal.

As a result of these comments, one action was that the Scottish Government would undertake a separate review of the valuation appeal system, beginning in 2014. This paper initiates that process, continuing the wider review of the Scottish business rates system ahead of the 2017 revaluation.

The Scottish Association of the Institute responded to this consultation paper.


IRRV Response


Institute raises concerns regarding guidance in HB Circular U6/2014.

Senior Vice-President Jim McCafferty has written to Welfare Reform Minister Lord Freud concerning the wording of HB Circular U6/2014.  Lord Freud’s reply accepts the point made by Mr McCafferty that It is over- simplistic to assume a link between rent set and the number of bedrooms; and that even in such cases where there is such a link the HB Decision Maker simply does not have the power to compel a change in rent.  The Minister undertook to issue guidance to clarify this position.

IRRV letter to Lord Freud re. HB Circular U6/2014

Lord Freud’s letter of response re HB Circular U6/14

HB Circular U6/2014

Consultation: Community Amateur Sports Clubs:

Consultation Launched: 3rd June 2013
Consultation Closes: 12th August 2013

  1. This 44-page consultation from HMRC lays out proposals to amend the qualifying conditions and allow clearer, more detailed, rules to be specified in secondary legislation following a public consultation. 
  2. The full consultation document can be found at:
  3. Chapter 4 sets out what is meant by the qualifying condition that a club must be ‘open to the whole community’. It focuses on the cost of membership and participation. The consultation seeks views on the maximum amount that a club can charge for membership and participation and qualify as a CASC. It proposes a maximum amount of up to £1,040 a year (£20 a week). This amount would include all the costs to a member for them to be able to participate in the sport.
  4. Chapter 4 also suggests how clubs that have to charge fees above the maximum amount might still be eligible for CASC status. Clubs would have to make appropriate arrangements to ensure those on low and modest incomes can fully participate. For example, a club could charge reduced rates for members on a low or modest income.
  5. Chapter 5 sets out the changes proposed to the qualifying condition that a club must be ‘organised on an amateur basis’. The consultation document proposes that a club can pay one player to play and that they can pay such a player a maximum of £5,000 a year.
  6. Chapter 5 also explores options for improving the current rules on expenses. Proposals include allowing clubs to pay players overnight subsistence costs such as hotels and evening meals in addition to travelling expenses. Chapter 5 also seeks views on the conditions that would need to be met if a club pays the expenses of playing members when they go on tour.
  7.  Chapter 6 proposes definitions of a social member and a guest for the purposes of the scheme. The chapter also seeks views on the percentage of social members a club should be able to have at any one time and still be considered a sports club.
  8. Chapter 7 seeks views on the detailed rules to apply to a new qualifying condition on income. The purpose of this condition is to specify how much social and other non-sporting income a club should be able to raise and still remain within the scheme. This chapter sets out four possible options.
  • Option 1 – Members income test. There would be no limit on any income from members. However there would be a limit on turnover from non-members of 20% as a percentage of total incomings of the club, capped at £25,000.
  • Option 2 – Basic income test. This is a simple test that would limit only non-sporting turnover of a club. The proposed limit for non-sporting income is 30% of the total turnover, capped at £100,000.
  • Option 3 – Different limits for different streams of income. This option would limit the turnover from various income streams such as the supply of food and drink (30%) and hiring of facilities (20%).
  • Option 4 – Days open test. This option would not limit the amount of income that is generated on the days sport was taking place. In addition the club could open on non-sporting days for a certain number of days through the year.
  1. The Government is seeking views on the details of these options and any views on alternative suggestions.
  2. Chapter 8 sets out the changes the Government is proposing to help certain clubs retain their CASC status where they have high levels of social income. One of those options would be to extend corporate Gift Aid, which currently applies only to donations to charities. Trading subsidiaries of CASCs would be able to pay little or no tax on their profits by donating their profits to their parent CASC.
  3. Chapter 8 also proposes to increase the Corporation Tax exemption limits for CASCs on trading income and rental income from £30,000 and £20,000 to £40,000 and £25,000 respectively.
  4. The Government also welcomes other suggestions for improving the qualifying conditions for CASCs.

Welsh Government Consultation - Business Rate Relief for Charities, Social Enterprises and Credit Unions – Recommendations from an independent report to the Welsh Government

Consultation launched: 23 April 2013
Consultation closes: 19 June 2013

In October 2012, the Welsh Government responded to the recommendations of the Business Rates Review Wales, an independent report from the Business Rates Task and Finish Group.   Recommendation 15 proposed consultation with the charitable and retail sectors to review the business rates reliefs that are available to charities and social enterprises.  The Minister for Economy, Science and Transport asked the Task and Finish Group to undertake this consultation and prepare specific recommendations on this issue.  The IRRV provided written and oral response to this process.

Their independent report has now been published and makes ten recommendations as well as further issues for consultation.

The Welsh Government seeks views on these recommendations. These responses will inform any further action that is taken. This consultation will run for eight weeks and builds on the engagement already undertaken by the Task and Finish and the previous call for evidence.

Summary of Recommendations:

Recommendation 1 - Use Planning Class

It is not recommended that a new Use Planning Class be introduced at this stage, but further consideration should be given to enabling the aims of such a change to be realised.

Recommendation 2 - Zoning

Any approach that is adopted to zone or limit the number of charity shops in a given area should be done at a devolved level of responsibility; this should be a matter for local authorities.

Recommendation 3 - Business Improvement Districts

Charity shops and their representative associations should be encouraged to fully participate as members of local organisations such as BID schemes that aim to rejuvenate and develop high streets in our towns and city centres.

Recommendation 4 - Bringing Long-Term Empty Property into Use

Any business which takes up new occupation of a property which has been vacant for 12 months or more would enjoy rate relief of 50% for the FIRST year of occupation.

Recommendation 5 - Bringing Long-Term Empty Property into Use

A business occupying a RETAIL property in a town centre that has been vacant for 12 months or more would enjoy 50% rate relief for TWO years. In addition, social enterprises may apply to have this 50% rate relief extended beyond two years at the discretion of the local authority.

Recommendation 6 - Tax Avoidance

The government should consider the following measure to tackle tax avoidance: all commercial premises that are occupied and used for charitable purposes could be subject to an upper RV limit of, say, £36K.

Recommendation 7 - Diversity on the High Street

New thresholds for charity shop rate relief should be created that will limit the amount of relief available for charity shops occupying premises of higher Rateable Value. These changes should be phased in for existing charity shops.

Recommendation 8 - Rateable Value Thresholds

The RV thresholds set out above should be reviewed at the time of the 2017 Rating List and subsequent Rating Lists. The threshold RVs may then rise or fall according to the tone of the List.

Recommendation 9 - Future Rating List

When the next Rating List for 2022 is introduced, consideration be given to reducing the mandatory 80% charitable relief to 50% for all charity shops and that as much as possible of charitable reliefs should be left to the discretion of the local authorities.

Recommendation 10 - Monitoring of New Goods Sales

To further address the issue of unfair competition on the high street, the amount of new goods being sold by charity shops be more effectivelymonitored by charitable organisations themselves (e.g. the CRA) - particularly in the run up to the Christmas period.

Download Wales NDR Charity Consultation

IRRV Comments:

DownloadDownload the IRRV comments in PDF Format


The implementation of welfare reform by local authorities

The House of Commons Communities and Local Government Committee announced in October 2012 that it was conducting an Inquiry into the implementation of welfare reform by local authorities.

The Committee invited submissions from interested parties covering the progress made to date on the implementation of welfare reform by local authorities. Those making submissions were asked to consider the following issues, though the list was not exhaustive and respondents could select which issues they wished to cover.

  • How effectively are the Department for Work and Pensions and the Department for Communities and Local Government working together to implement Welfare Reform?
  • Is the guidance available to local authorities from central government on implementing welfare reform adequate? Are there areas where more or better guidance is required?
  • Is the Government’s timetable for implementing Welfare Reform achievable?
  • Are local authorities being allocated sufficient resources to deliver services such as localised Council Tax Support and advice to claimants on Universal Credit?
  • Are there financial risks to local authorities from Welfare Reform changes? Are such risks being adequately addressed?
  • What impact have Welfare to Work schemes had, or are likely to have, on the numbers of benefit claimants?
  • What evidence is there that local authorities are able to use effectively existing services or contracts for the delivery of new local Social Fund schemes?
  • How will the separation of the administration of Council Tax Benefit and Housing Benefit affect claimants?
  • How significant an issue is housing benefit fraud under the proposed new system and what measures are being taken to address it?
  • Are there sufficient safeguards to protect social landlords from financial harm resulting from the payment of housing benefit direct to claimants?

The Institute submitted its evidence by the 14th December 2012 deadline. 

Download the Institute's response


Transforming bailiff action

This Ministry of Justice consultation paper sets out proposals for transforming bailiff action and providing more protection against aggressive bailiffs.  The aim of the proposals is to simplify and clarify the process, improve the accountability of enforcement agents and address unnecessary or inappropriate enforcement activity. Deadline for responses: 14th May 2012.

Link to Consultation

IRRV Response

Costs in Tribunals:Report by the Costs Review Group to the Senior President of Tribunals

Joint Response by: the Royal Institution of Chartered Surveyors; the Institute of Revenues, Rating and Valuation, and the Rating Surveyors’ Association

A joint response to the ‘Costs in Tribunals’ Report, submitted by the Royal Institution of Chartered Surveyors; the Institute of Revenues, Rating and Valuation; and the Rating Surveyors’ Association.

Link to Consultation

IRRV Response

IRRV Evidence: Welsh Government Business Rates Policy Review

Call for evidence: Business Rate Policy Review

"We want your evidence and views on options for how the business rate
regime and related rate relief schemes can be modified to better encourage
economic development."
Welsh Government
Start of consultation:  05/12/2011
End of consultation:  27/01/2012 

Link to Consultation

IRRV Response




More Consultations

Land Transaction Tax (LTT) consultation

Closing Date 6th May 2015

LTT replaces Stamp Duty Land Tax in Wales from April 2018.

The devolution of some taxes to Wales from April 2018 provides Welsh Government with the opportunity to reshape those taxes to better meet Welsh circumstances and priorities.

The Minister for Finance and Government Business is encouraging members of the public and organisations  across  Wales and the UK to get involved as Wales takes greater control of its financial future.    

Land Transaction Tax will replace the current UK Stamp Duty Land Tax in Wales in 2018.  This will affect many of us across Wales, including:

  • home buyers and sellers
  • builders, developers or investors in property
  • businesses renting premises in the non-residential markets
  • those who play important roles in the transaction processes. 

The Minister has set out her principles for the Welsh taxes and made it clear that they should be fair to people and businesses, support growth and jobs, which in turn will help tackle poverty and support communities. 

The consultation seeks views on how the current system can be improved in order to make it more effective, efficient and better suited to the priorities and needs of Wales.

Link to consultation

Welsh government has also produced a leaflet on Welsh Taxes which can be viewed at this link:

Business Rates: New Build Empty Property (England only)

Consultation launched: 12th June 2013
Consultation closes: 26th July  2013

1.      This 11-page consultation from DCLG lays out proposals to exempt all newly built commercial property completed between 1 October 2013 and 30 September 2016 from empty property rates for the first 18 months, up to the state aids limits. This document sets out the government’s proposals for the delivery of that policy and seeks consultees’ views on them. The full consultation document can be found at:



Parliamentary Work and Pensions Committee: Inquiry into Jobcentre Plus (JCP).


Opening date: 19 April 2013.

Closing date: Friday 24th May

The inquiry will focus on the services JCP offers to benefit claimants, jobseekers and employers and its relationships with external providers and stakeholders such as local authorities, in the context of recent and ongoing welfare reforms,  including the introduction of  Universal Credit, and the resulting changes to JCP staff roles.

The Committee will consider the future of JCP as a public employment service, including its role as “gatekeeper” to contracted-out services such as the Work Programme and Work Choice. It will also assess the support which JCP currently provides to jobseekers in the early months of their unemployment benefit claim, before referral to external providers.

The inquiry will also assess whether the organisational changes in JCP since 2011 have produced efficiencies and streamlined management processes as intended.

Submissions of no more than 3,000 words are invited from interested organisations and individuals.  The Committee is particularly interested in the issues set out below. Submissions do not need to address all of these points.

  • JCP’s employment services, including: approaches to identifying jobseekers’ needs and barriers to employment; the effectiveness of the “Get Britain Working” measures; JCP’s role as a gateway to contracted-out services such as Work Choice and the Work Programme, including processes for referral and handover; JCP’s use of the Flexible Support Fund, including how spending decisions are made and evaluated; and the effectiveness of JCP’s relationships with other key stakeholders, particularly local authorities.
  • JCP’s role in relation to the rights and responsibilities of benefit claimants, including: the effectiveness of benefit conditionality, particularly job-seeking conditionality and the mandatory “work-focused interview”; and the level and appropriateness of JCP’s use of benefit sanctions, including differences of approach between JCP Districts. 
  • Supporting a flexible labour market, including: JCP’s effectiveness  in matching jobseekers to suitable job vacancies, including through the introduction of Universal Jobmatch; whether JCP is sufficiently focused on sustained job outcomes as well as off-benefit flows and how this is, or should be, measured; and employers’ assessment of the effectiveness of JCP as a recruitment partner.
  • The impacts of benefit reforms, including: the implications for JCP staff roles of the implementation of Universal Credit, including the skills staff will need in order to offer effective in-work support; changes to staff roles brought about by the move to “digital by default”; and plans to support claimants affected by the benefit cap
  • The governance of JCP, including: whether ending the executive agency status of JCP, and bringing it under the central control of a single DWP Chief Operating Officer, has brought about efficiencies and streamlined management as intended; and the potential for more radical future changes to JCP. 

IRRV Response:

DownloadDownload the IRRV submission in PDF Format


21st Century Welfare Consultation

(1 October 2010 deadline)

Through this consultation the Department for Work and Pensions seeks views to inform its thinking on reforms to the benefits and Tax Credits system, including the idea of a single integrated Universal Credit. The full consultation paper can be found at:

Link to consultation

The full consultation paper can be found at:

IRRV Response:

DownloadDownload the IRRV submission in PDF Format

06/02/2013 / 1476

Dynamic Benefits

The President of the Institute has received the following reply to our 105 questions from the Minister for Welfare Reform. We will be following this up immediately as well as sending further questions. As we get the answers we will post them on the website in a specific area that will be open to all.

Response from Lord Freud

Letter to Lord Freud

The position of the Institute has been to support the principles behind Dynamic Benefits and further to support the introduction of the Universal Credit; however the IRRV cannot support the inclusion of housing costs in Lord Freud's proposals.

Below is a draft of the letter sent to Lord Freud by the Institutes President Kerry Macdermott

My Institute is the only professional body in the United Kingdom that specialises in the law and practice of local authority revenues and local taxation collection together with the income related benefits that support these processes.

The position of the Institute has been to support the principles behind Dynamic Benefits and further to support the introduction of the Universal Credit; however we cannot support the inclusion of housing costs in your proposals.

There are many reasons behind this statement and in order to give your officials every opportunity to advise you to step back from a potential disaster that will make the Community Charge pale into insignificance we wish to offer you a constructive dialogue which will assist your thinking. The dialogue will be in the form of a series of questions which we hope, as you answer them; will give you an insight into the problems you will be facing.

The questions will be posted on the open area of our website and we will post the answers as your officials provide them. We hope you will welcome this approach and allow every opportunity for a constructive dialogue to take place which will assist you in the difficult decisions you will have to make over the next two years.
The first one hundred or so questions are attached and these have all been raised by practitioners as important issues that will need to be addressed to ensure a successful implementation of the Universal Credit.

May I also take this opportunity to personally thank you for the support you have given the Institute at our recent conferences. If your officials need any clarification on the questions, can they contact the Institutes Chief Executive David Magor

Link to 105 First Questions

DownloadDownload Questions 

Download Letter



02/05/2013 / 1498