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Policy and Consultations:

2024 Consultations - Closed

  • The IRRV responds to consultations that are relevant to the membership and profession across all the Institute’s faculties.  Most consultations of interest are issued by the UK national governments on legislative matters, but responses can be made to papers emanating from the private and non-profit sectors and from international bodies. 

    This work is undertaken under the guidance of the Law and Research Portfolio Holder.  Drafting is developed with the input of the  Institute’s Faculty Board members.  Issues being consulted upon can often span the interests of two or more Boards; it is a strength of the Institute’s responses that they reflect that wider professional viewpoint.

  • This technical consultation was of interest to employers, businesses and their advisors who are operating at Freeport and Investment Zone special tax sites. It was also of interest to payroll software developers.

    The draft regulations introduced a new reporting requirement for Freeport and Investment Zone employers who claim the NICs reliefs to provide a workplace postcode for employees they claim the NICs reliefs in respect of.

    The consultation could be found at https://www.gov.uk/government/consultations/freeport-and-investment-zone-employer-national-insurance-contributions-reliefs?utm_medium=email&utm_campaign=govuk-notifications-topic&utm_source=37434c4f-c6d0-4f09-8b62-588bd3327aef&utm_content=daily

    The consultation closed on Wednesday 15 May 2024.

    Responses could be sent to nics.correspondence@hmrc.gov.uk.

  • The Welsh Government welcomed views on proposals to abolish land transaction tax (LTT) multiple-dwellings relief, and to extend an existing LTT relief to Welsh local authorities when purchasing property for social housing purposes. The Welsh Government was also interested in views on the option of amending the rules related to the purchase of 6 or more dwellings in a single transaction, and options to review or amend other LTT reliefs. The Welsh Government will make a statement regarding the next steps once the consultation has closed and the responses have been considered.

    The consultation could be found at: Proposed changes to land transaction tax reliefs | GOV.WALES

    The deadline for response was 19 May 2024.

  • Support with Council Tax payments through the Welsh Government’s Council Tax Reduction Scheme (‘the scheme’) is an important part of welfare support for households on low incomes. The scheme, which is administered locally by councils, has historically had low take-up from potentially eligible residents and the number of households receiving a Council Tax reduction continues to fall. 

    This technical consultation proposed a number of changes to the scheme to make it easier to access and simpler to administer. Nothing in this consultation placed new restrictions on existing eligibility for the scheme. 

    The consultation could be found here.

    Closing date for responses was 6 June 2024.

    The IRRV's response can be found here: IRRV-response-council-tax-reduction-scheme-Wales-May-2024.pdf

  • The Money and Pensions Service (MaPS) consulted on its proposals for the delivery of its debt advice strategy.

    The consultation set out MaPS' approach to debt advice up to 2028. It explored how they interpret their remit in relation to debt advice and the role that they could take in working with the wider debt sector on some of the key issues and challenges identified.

    The consultation could be found at https://maps.org.uk/en/publications/consultations-and-responses/2024/consultation-on-MaPS-proposals-for-delivery-of-debt-advice-strategy#

    The closing date for responses was 3rd April 2024.

  • Senedd Cymru’s Local Government and Housing Committee released a consultation scrutinising the Local Government Finance (Wales) Bill.

    Specifically, the Bill scrutinised:

    • The general principles of the Local Government Finance (Wales) Bill and whether there is a need for legislation to deliver the Bill’s stated policy objectives (see the Bill page for further details).
    • Any potential barriers to the implementation of the Bill’s provisions, and whether the Bill and accompanying Explanatory Memorandum and Regulatory Impact Assessment take adequate account of them.
    • Whether there are any unintended consequences arising from the Bill.
    • The Welsh Government’s assessment of the financial and other impacts of the Bill as set out in Part 2 of the Explanatory Memorandum.
    • The appropriateness of the powers in the Bill for Welsh Ministers to make subordinate legislation (as set out in Part 1: Chapter 5 of the Explanatory Memorandum).
    • Matters relating to the competence of the Senedd including compatibility with the European Convention on Human Rights.
    • The balance between the information contained on the face of the Bill and what is left to subordinate legislation.
    • Any matter related to the quality of the legislation.
    • Any other matter related to the constitutional or other implications of the Bill.

    The consultation could be found here.

    The deadline for response was 15th January 2024. The IRRV response is at IRRV_Response_LGFBill_150123.pdf

    On 15th March 2025, the Local Government and Housing Committee’s Stage 1 report on the Local Government Finance (Wales) Bill was published here.

    Having considered the evidence presented on the broad range of provisions in this Bill, it was concluded that, on balance, and taken in its entirety, they support its general principles. However, it is evident that there are a number of areas on which further consideration by the Welsh Government is necessary. This report details their consideration of each of the provisions within the Bill and their subsequent recommendations, which seek to make the improvements they believe are needed to strengthen this legislation.

  • Internal drainage boards (IDBs), which are locally funded and operated statutory public bodies, are responsible in their area of operation, for water level management and managing flood risk. There are 112 independent IDBs in England and they are mainly funded by the beneficiaries of their work, through drainage rates on agricultural landowners and special levies on local authorities. 

    IDBs use a land valuation calculation to apportion their expenses between landowners and local authorities. This is based on historic ratings data which is missing or incomplete and is preventing new IDBs from being created and existing IDBs from expanding their boundaries. 

    To address this, the government has made a technical change to the Land Drainage Act 1991, via the Environment Act 2021, setting out a new valuation calculation which enables the use of more up-to-date data from the Valuation Office Agency. This approach will apply to drainage rates and special levies, to ensure consistency in the apportionment of expenses. 

    The consultation started on 7 March 2024 and was open for a period of 6 weeks closing on 19 April 2024.

    The consultation could be found at: Consultation on draft Statutory Instrument: The English Drainage Boards (Alternative Valuation Calculation) Regulations 2024 - Defra - Citizen Space

    The IRRV response is at IRRV_response_Consultation_on_IDB-regs.pdf

  • ECB’s draft Business Plan for 2024/25 was open for consultation.

    This consultation paper introduced the Enforcement Conduct Board’s (ECB) draft business plan for 2024/25. The 2024/25 business plan was the second of their full business plans. A draft was presented in Annex A to this consultation, which set out their key strategic priorities and planned deliverables for the year ahead.

    The consultation could be found at https://enforcementconductboard.org/our-work/#businessplan

    Closing date for responses was 4 April 2024.

    The IRRV response is at IRRV_response_Consultation_on_ECB_Business_Plan_030424.pdf

  • The government consulted on a proposal to include the claimant’s name in entries about money judgments on the Register of Judgments, Orders and Fines.

    The consultation sought views on:

    • the potential benefits of including claimant names on the Register
    • any potential disadvantages and/or risks to either the claimant or defendant as a result of the publication of this data.

    The consultation could be found here.

    The deadline for response was 16th January 2024.

  • The Bankruptcy and Diligence (Scotland) Bill contains powers which would allow Scottish Ministers to create a Mental Health Moratorium. This would protect people with serious mental health issues from debt recovery action. Scottish Government sought views on the proposed process for a Mental Health Moratorium.

    The consultation could be found here

    The deadline for response was 22 January 2024.

    The IRRV response is at IRRV_Response_Mental_Health_Moratorium_Final.docx

  • The Special Public Bill Committee on the Arbitration Bill [HL] issued a call for evidence on the Bill.

    The House of Lords has established a Special Public Bill Committee on the Arbitration Bill [HL]. The long title of the Bill is “Bill to Amend the Arbitration Act 1996”. Special Public Bill Committees are empowered to take written and oral evidence on a Bill before considering it.

    The Committee welcomed views on the provisions contained within the Bill, and any other matters that would be considered to be relevant to the subject matter.

    The consultation could be found here.

    The deadline to submit written evidence was 6 February 2024.

  • The Welsh Government were looking at different ways of bringing the Council Tax system up to date and making it fairer. This included the potential to introduce new Council Tax bands.

    As part of their consultation, they sought views on:

           • different approaches for new Council Tax bands

           • regular updates to Council Tax in the future

           • discounts and exemptions

           • a more transparent system and a more effective appeals process

    The purpose of the reforms would be to ensure that Council Tax contributions are more fairly spread and reflect the latest information available about economic circumstances. None of the approaches outlined in this consultation represented a revenue-raising exercise.

    The Programme for Government and the Co-operation Agreement commit to reforming Council Tax to make it fairer and more progressive. It remains the firm intention of both the Welsh Government and Plaid Cymru to make progress on the journey to a fairer system in Wales.

    A more progressive tax looks to lower the share of tax paid by those who are less able to contribute, making things fairer. This may be difficult to achieve all at once, so we’re asking for your views about the approach we take to make the system fairer. The evidence shows the changes we’re proposing would reduce longstanding wealth inequalities created by an unfair system.

    This consultation sought views on how and when changes to the basic structure of Council Tax in Wales should be made and update the property valuations used.

    This consultation provided an update on reviews of these arrangements and proposals for:

        • modernising the service provided to taxpayers

        • taking powers to reform the system of discounts and reductions over time

        • committing to retain the one-adult discount and to keep the level of discount at 25%

        • changing the treatment of empty properties to remove the obligation on councils to offer a 50% discount on most empty properties (councils will maintain their discretion on    caravans and houseboats, on homes where the owner has died and job-related dwellings)

       • changing the time-limits for exemptions on properties in probate

       • amending the language we use, and the system in place, to provide help to those with a ‘severe mental impairment’

       • improving the Council Tax Reduction Scheme

    The consultation could be found here

    The deadline for response was 6th February 2024. 

    The IRRV response is at fairer-council-tax-response-form-IRRV.pdf

  • The Department of Finance launched a 14-week consultation on the revenue raising potential associated with the removal of rating measures.

    The consultation followed a direction from the Secretary of State for Northern Ireland Rt Hon Chris Heaton-Harris MP, directing Northern Ireland departments to launch public consultations on measures to support budget sustainability and raise additional revenue.

    The Department sought views from those who may be directly affected and from the wider body of ratepayers. There were seven proposals for changes to rating measures identified by the Secretary of State:

    Domestic sector: Early Payment Discount, Landlords Allowance, Maximum Capital Value cap.

    Non-domestic sector: Non-domestic Vacant Rate relief, Industrial Derating, Freight Transport relief, Halls of Residence exemption.

    The consultation could be found here.

    The deadline for response was 13th February 2024.

    The IRRV response is at IRRV_response_Consultation_on_Non-domestic_and_Domestic_rating_measures_to_support_budget_sustainability.pdf.

  • This consultation sought views on the Welsh Government’s proposals to amend the Land Transaction Tax and Anti-avoidance of Devolved Taxes (Wales) Act 2017. The amendments will provide a relief from land transaction tax for qualifying transactions within a designated Welsh special tax site.

    Annex B set out the draft legislative provisions contained within The Land Transaction Tax (Relief for Special Tax Sites) (Wales) Regulations 202[4].

    While there was no statutory duty to consult, consulting at this stage respected well established public law principles, as there was likely to be a legitimate expectation that the Welsh Government will consult on this matter. This consultation ran for a period of 8 weeks, which was shorter than the standard consultation period of 12 weeks. Given the technical and area specific nature of the draft legislative provisions, a shorter public consultation exercise was deemed reasonable in the circumstances.

    The consultation could be found here.

    The closing date for responses was 18 February 2024.

  • The Department for Infrastructure launched a consultation on options for introducing water and sewerage charges.

    The consultation, which had its content approved by the Secretary of State for Northern Ireland, provided an overview of potential water and sewerage charging revenue-raising options that could have been introduced in Northern Ireland, with a focus on creating sustainable public finances.

    It set out and sought views on the main pathways through which water and sewerage charging could be introduced, how a relief scheme to protect vulnerable people might have been developed, and how charging might have been billed and collected.

    It also asked about three other revenue-raising options:-

    • Charging customers for domestic septic tank desludging.

    • Recovering the cost of roads drainage from all customers.

    • The removal of the domestic allowance for non-domestic customers.

    All non-domestic customers in Northern Ireland are charged for water and those who discharge to the public sewer are also subject to sewerage charges, and trade effluent charges where applicable. In cases where a property is used for both non-domestic and domestic purposes, the use of water and sewerage is considered as non-domestic use.

    A domestic allowance is a free volume of water and/or sewage which is subtracted from the volume as recorded by the meter, before calculating the volumetric charge. This revenue raising option would involve the removal of the allowance currently received by non-domestic customers for domestic usage, meaning that such customers would be required to pay more.

    The consultation could be found here.

    Closing date for responses was 13 March 2024.

    The IRRV response is at IRRV_response_Consultation_on_Water_and_Sewerage_Charges_Northern_Ireland.pdf

  • The Minister for Finance and Local Government intended to put before the Senedd a proposal to change land transaction tax rules to allow homebuyers, in specified difficult circumstances, extensions to the current 3-year periods.

    The proposal will be put before the Senedd once the responses to this consultation have been considered.

    The consultation could be found here.

    The closing date for responses was 17 March 2024.

  • RICS members and external stakeholders such as industry bodies, government, pub tenants and owners requested an update to the 2010 guidance note Valuation of licensed leisure property, including public houses, bars, nightclubs and restaurants, 1st edition. In a specialist market such as licensed leisure, the provision and consideration of professional advice can be complex. 

    This consultation was an opportunity to shape the updated professional standard related to the economically and culturally significant licensed leisure market sector, which has evolved substantially in recent years. It allowed people to give their views on what needs updating and how.

    The consultation could be found at: Valuation of licenced leisure property 2nd edition (rics.org)

    The deadline for response was 14 June 2024.

    The Institute's response can be found here IRRV_Response_Consultation_on_Valuation_of_Licenced_Leisure_Property_2nd_Edition.pd

  • A call for evidence to inform a programme of work announced at the Autumn Statement in 2023. It was part of a wider suite of activity to reform the fit note and acted as a prelude to a full consultation on specific policy proposals which will be launched later this year.

    The call for evidence could be found at https://www.gov.uk/government/calls-for-evidence/fit-note-reform-call-for-evidence?utm_medium=email&utm_campaign=govuk-notifications-topic&utm_source=95e98dfc-e490-4c45-ac95-3e5f354b9025&utm_content=daily

    This call for evidence was open until 8 July 2024.