Reforming the non-domestic rates system: consultation analysis

Executive Summary

On 22 September 2021, the Scottish Government launched a 'Consultation on reforming the non-domestic rates system: proposals, the draft valuation roll, content of valuation notices, etc.'. This sought views on reforms to the non-domestic rates system in the context of three-yearly revaluations and a one-year tone date from 2023, as well as the introduction of a two-stage appeals system scheduled to be introduced on 1 January 2023.

The consultation closed on 15 December 2021 and received 37 responses all of which were from organisations. A list of respondents and links to their responses is available in Annex A where permission has been given to publish these responses. We would like to express our sincere thanks to those that submitted a response to the consultation.

Summary of responses

The consultation asked for views on five draft Scottish Statutory Instruments (SSIs):

• the draft Valuation (Proposals Procedure) (Scotland) Regulations 2022
• the draft Valuation Timetable (Scotland) Amendment Order 2022
• the draft Valuation Timetable (Scotland) Amendment (No. 2) Order 2022
• the draft Valuation Roll and Valuation Notice (Scotland) Order 2023
• the draft Non-Domestic Rates (Valuation Notices) (Scotland) Regulations 2022

In summary, respondents expressed concern over the procedures and timescales set out in the draft Valuation (Proposals Procedure) (Scotland) Regulations 2022, particularly the information-sharing requirements at the point of lodging a proposal. A publication date of 30 November the year before revaluation for the draft roll was broadly welcomed by some of those who commented on this point the provision of additional information in the draft Non-Domestic Rates (Valuation Notices) (Scotland) Regulations 2022. Many however called for the provisions to go further, and stated that it was unfair, particularly at the point of lodging proposals, that some property types would have additional information provided in the valuation notices, and others would not.

About the analysis

As with all consultations it is important to bear in mind that the views of those who have responded may not fully reflect the views of the wider population. Individuals (and organisations) who have a keen interest in a topic – and the capacity to respond – are more likely to participate in a consultation than those who do not. This self-selection means that the views of consultation participants cannot be generalised to the wider population.

It is worth noting that a significant number of responses had very similar wording in some parts, and also that a number of the organisations who responded are also members of other organisations that provided a response.

For this reason, the approach to consultation analysis is primarily qualitative in nature. Its main purpose of this analysis is not to identify how many respondents held particular views, but rather to understand the full range of views expressed.

Next Steps

Responses to the consultation have informed policy development in relation to the draft SSIs that were consulted on. Additional analysis of the information received in response to this consultation can be found below.