Question 16: Would you use a service that allows you to view business rates information for all your properties across England in one place, alongside other HMRC tax liabilities? Yes/No
- If yes, how often and for what purposes?
- If yes, how useful would you find such a service – on a scale of 1 to 10, where 10 is extremely useful?
- If no, would being able to pay your bill(s) through the service change your response?
This question is addressed to ratepayers, but we can also see that billing authorities would have a clear interest in using a service, for example for checking eligibility to reliefs. We note and welcome that the consultation says that DBR should not change the billing authority’s responsibility for business rates, so that any future billing functionality should link to the billing authority.
Question 17: When thinking about how often (your) bills change, how often should the business rates billing information be updated? (for example, daily, weekly or whenever a ratepayer seeks to view their billing information). Options: real time look up/daily/weekly/monthly/quarterly/annually.
This question is primarily addressed to ratepayers. However, we would note that liability for business rates is determined on a daily basis and circumstances can change every day. Therefore, any service should be updated at least daily. Ideally any changes should be notified and billing authority systems updated automatically so that billing authorities do not have to clean data, although there may be an initial data clearing exercise.
Question 18: Could DBR data help with targeting and administering reliefs? If so, for which reliefs would it be help most and why?
Responsibility for determining and awarding reliefs is that of the billing authority. We can see that a service could, at least in theory, help billing authorities with both mandatory and discretionary reliefs as long as it gave billing authorities the ability to look at data for ratepayers with properties both in their own and other billing authorities.
We would anticipate that a DBR system could most immediately help with mandatory reliefs such as small business rates relief and that it could also have a role in checking on entitlement to charitable relief and empty property relief. This is because it would enable billing authorities to see if ratepayers met the eligibility criteria for small business rates relief, for example by checking for potential occupation and valuation of properties in other billing authorities.
We are concerned about business rates compliance and avoidance. Based on a 2019 survey we estimated that around £250 million per annum, or about 1 per cent of total business rates income, is lost to avoidance. We are particularly concerned about the abuse of reliefs such as empty property and charitable relief, as well as small business rates relief and abuse of insolvency legislation. A digital business rates service, could, at least in theory, give councils new tools to combat business rates avoidance, although we remain of the view that the Government should change the regulations to tighten up on all business rates avoidance including, for example, taking advantage of the six weeks occupation to qualify for another period of business rates relief and enacting a general anti-avoidance rule (GAAR). Similar measures have been enacted or are proposed in Wales and Scotland
Question 19: Is there any other data that DBR could provide to help billing authorities feel more confident when awarding reliefs and/or grants?
Some reliefs and grants are subject to subsidy control rules and these generally apply for the business as a whole. The normal practice in this case is that the ratepayer certifies that they are not in breach of subsidy control limits, but there is no way of checking across authorities. DBR could provide a way of checking on subsidy control limits, although it should be recognised that this would place more new burdens on councils and should be funded accordingly.