7 February 2018
Members are reminded that if they or their clients have received sporting rights valuation notices from their regional Assessor, any appeal against that valuation must be made within 6 months of the notice, otherwise the opportunity to contest the valuation is lost until the next national revaluation (or possibly on a change of ownership/occupier).
And we suggest to members not to rely on any rates relief they may be able to currently claim under the Small Business Bonus Scheme - see https://www.mygov.scot/small-business-bonus-scheme-scotland/
This relief is subject to annual review, and last year was a focus of the Barclay Review on non-domestic rates – it may not be there in the future! Certainly claim whilst ye may, but we do not think it should be regarded as a reason not to appeal your assessment.
Confor believes it is important that forest owners and managers should appeal their assessments, as apart from anything else, uncontested valuations provide the Assessors with evidence. The Assessors did not have the time nor the resources to do a thorough job before they had to issue the first tranche of valuation notices. Disability allowances and regional/geographical differences have not been taken into account, nor have “factors relating to deer management” been addressed (as provided for in the legislation). These are all matters which could make a very material effect upon a sporting rights valuation. However, changes to your valuation assessment will now have to be sorted out through the rating appeals process, and it is unlikely that these will be heard for some considerable time.
The valuation method of a flat rate per hectare (£5/ha for woodlands) is a very blunt tool as it presently stands, and we believe that in time, and as various appeals are settled, many commercially managed forests - where deer control is the key element rather than sport – will be re-assessed to nominal and in some case nil value. We will monitor that process and advise you further as significant decisions are reached. Meanwhile we will continue a dialogue with the Scottish Assessors Association (SAA), and with Scottish Government.
The SAA are independent of government, so if any progress could be made with obtaining any further relief or exemption from rates for (commercial) forestry, that would require legislative change. We know from Cabinet Secretary Fergus Ewing’s comments in December to the REC (Rural Economy & Connectivity Committee) that forestry was not really the target for this new tax, and we will pursue this aspect.
Confor does not argue with the concept that sportings on lands & heritages (including woodlands) must now be placed on the valuation roll. We simply seek a just and equitable valuation for forestry which properly reflects reality on the ground. We have therefore worked with Scottish Land & Estates and other rural organisations in writing to Scottish Government, and agreed the following communication statement to our respective members:
Rural organisations have written to Scottish Government Cabinet Secretaries setting out their concerns for the sector following the reintroduction of non-domestic rates on shootings and deer forests.
Scottish Land & Estates, Confor, Scottish Countryside Alliance, NFU Scotland, BASC, ADMG, and SACS have written a joint letter to Fergus Ewing, Cabinet Secretary for Rural Economy and Connectivity, and Derek Mackay, Cabinet Secretary for Finance and the Constitution. The letter expresses concern that the re-introduction is being rushed, Assessors have not had time or resource to implement the reintroduction satisfactorily, and it is rural businesses and communities that will suffer the consequences.
The organisations have welcomed further dialogue with the Scottish Government and seek the consideration of how unintended impacts on policies, such as those regarding deer management and forestry, can be mitigated. Breathing space would allow businesses to plan while accuracy of valuations is established through the appeals process and the Scottish Government can undertake impact assessments which would fulfil their commitment set out during the Bill stages.
It is hoped this collaborative working and engagement will help with the understanding of how this reintroduction is unintentionally detrimentally affecting rural areas.