Back in 2017, all commercial properties in Great Britain were re-valued for the 2017 Rating List and the new Rateable Values were set live. During this time, properties in England had to undergo a radical change to the business rates system as a new process was put into place called Check, Challenge, Appeal (the CCA System). The new system that was introduced brought in a completely new process for both the ratepayer as well as their agent. A newly digitalised method, it allowed both parties to complete a series of online processes before any appeal action could be taken. This CCA process can be broken down into the following four parts:
- Government Gateway Account
If you in already own a Government Gateway Account for your business then this can be used for the purposes of the CCA system registration. If you don’t, then you will need to set one up as part of the sign in process on the VOA portal. For ease of use, you can find the portal by clicking here.
- Valuation Office Agency Personal ID
The person that registered with the Organisation Government Gateway Account will have to go through a personal ID route with the Valuation Office Agency (VOA). As part of this, as the owner, you will need to provide your National Insurance Number, passport details as well as your current home address.
- Register Your Business
The business details needed by the valuation office include the name of the business, the address of the business along with your personal details such as your email so your documents can be given to you formally.
- Linking & Agent Appointment
The final step once the above 3 are complete is to claim each of your properties. Following this, you can then appoint your agent such as Roger Hannah & Co to undertake your checks and challenges on your behalf. To claim a property, you need to identify it in the rating list and then submit evidence normally a copy of a rate demand to prove your interest in the property. At the same time, you can appoint an agent to act on your behalf. To appoint ourselves as your agent, the unique Roger Hannah & Co Agent Code is 37706.
The CCA Process
The Valuation Request
The first part of the CCA process. The VOA portal does offer valuations; however, there are several cases where the valuations aren’t available and are not published. It is only until the registration and property links part is complete that copies of these restricted valuations can be requested and given. Simply put, the Check cannot commence without a copy of the valuation.
This requires validation of the VOA’s property survey data as well as full disclosure of all physical changes to said property.
If a change to the property is required, for example, part has been sublet then full details of the changes including floor plans need to be submitted at the Check phase. Likewise, details of material changes need to be flagged to the VOA via the Check process.
Once a check has been submitted the Valuation Officer will review any changes detailed in the Check and where appropriate will amend the rateable value but be warned rateable values can increase as well as decrease. The VOA is aiming to clear checks within 12 weeks of submission but they do have up to 12 months to respond.
Once a Check has been concluded there is a 4-month window of opportunity to then Challenge the basis of valuation. With that being said, for material changes, the window is 16 months from the date of submission to allow the gathering of evidence.
The challenge part can only be submitted following the completion of the Check. Please note that there are strict time limits for submission of a Challenge. The responsibility herein lies with the person who is paying the rate or alternatively their appointed agent, who needs to serve a full and detailed submission. This submission must include elements such as the valuation, case law, legal arguments, comparisons and the evidence. It is then at this point that the VOA will show their evidence to support their given value. With both cases made, a discussion can then begin to negotiate (if possible) a fair outcome. The VOA will issue a decision on the Challenge within 18 months otherwise it is deemed to have been concluded and there is then the right to appeal.
The final stage – an appeal can be made to the Valuation Tribunal for England, also known as the VTE. This appeal can be made within four months of the VOA decision notice or after eighteen months have elapsed from the date of the Challenge. The Ratepayer (or their advisor) has to submit the full bundle of evidence and correspondence to the VTE. In addition, a fee of £150 for a small property and £300 for any other property is payable by the ratepayer for submitting an Appeal. If successful, the fee will be refunded in full or in part (in part if decided without an oral hearing).
If you’re looking to appoint an agent or would like some assistance with the CCA system and its process, please don’t hesitate to get in touch with us today. Our business rates team can help you every step of the way.