Business Rates Revaluation 2017
Local Taxation Division - Department for Communities and Local Government
26 October 2016
Dear Sir / Madam,
BUSINESS RATES REVALUATION 2017 AND TRANSITIONAL REARRANGEMENTS
South Bank Employers’ Group is pleased to respond to DCLG’s consultation on this important issue. This response supports and reinforces submissions made by South Bank Business Improvement District and South Bank Partnership. All three bodies are signatories to the joint submission made by over 20 London business organisations. Copies of all three documents are attached with this submission.
This is an issue that is of vital concern for all businesses and employers in London’s South Bank. It is one that has profound implications for jobs, growth, investment, economic development and a wider set of socio-economic issues. As in other parts of central and inner London, the combination of the revaluation and the introduction of a high cap for “large” businesses is a potential disaster for South Bank.
Businesses in South Bank make a significant and ongoing financial contribution to a number of important neighbourhood services - these are threatened if businesses are not supported with a fairer approach to transitional relief. We ask that Government revisits its options regarding the cap on large businesses, and reduces it further than 33% outlined in option 1. Furthermore, we ask that Government considers additional options for mitigating the impact of the revaluation, and ultimately looks to a longer term restructuring of how London businesses are taxed.
South Bank Employers’ Group (SBEG) was formed in 1991 as a not for profit company to represent the collective ambition of those businesses, cultural and arts organisations, social enterprises, statutory agencies, public institutions and infrastructure providers on London’s South Bank. Following 25 years of success in transforming the area, the ongoing commitment to SBEG reflects members’ desire to see South Bank remain as one of the most culturally and economically dynamic parts of London and the UK.
SBEG brings together a diverse group to achieve a shared vision - one that is based on economic competitiveness, creative diversity, and a firm commitment to those issues that matter to the local business and residential community - a quality public realm and environment, social amenities and facilities, and access to jobs and training opportunities for local residents. Our members are listed at the bottom of the page: most of internationally preeminent in their respective fields, whether commerce, property, education, health, culture, transport, hospitality, media and tourism.
Many successful initiatives have arisen from SBEG’s activities, including the South Bank Partnership (SBP) - jointly chaired by Kate Hoey MP and Neil Coyle MP - and South Bank Business Improvement District (SBBID), which has been operating since 2014, and includes over 170 levy paying members.
SBEG, SBP and SBBID have a common vision - to make South Bank and Waterloo:
- a desirable destination for culture, business and pleasure
- a place which supports and encourages investment and business growth
- a place with a flourishing and cohesive residential community
- a place which is welcoming to visitors and tourists
- a friendly, clean, colourful, safe, dynamic and diverse area
South Bank is one of London’s greatest successes - its contribution to London’s economy is approximately £2.8bn per annum, and is forecast to grow by 30% in the next 10 to 15 years - in an area that’s just 0.2% of London’s footprint. South Bank receives over 30 million visitors each year, and this will undoubtedly increase as the area continues to develop economically.
Recent research undertaken by SBBID estimates that the area contributes approximately £66m in business rates each year, which equates to over 40% of Lambeth’s total annual business rates income, and approximately 7% of Southwark’s total annual business rates income. It is estimated that this figure equates to 1% of London’s overall business rate contribution.
South Bank and Waterloo is recognised as an Opportunity Area by the Mayor of London, the Greater London Authority, Lambeth Council and Southwark Council. Economic growth targets are articulated through the Opportunity Area Planning Framework and, ultimately, the London Plan. Economically, South Bank matters.
South Bank Businesses: Funding and Investing in Neighbourhood Services
South Bank is under increasing pressure. The combination of rising numbers of tourists and visitors, business and economic growth, and constant pressures on public services means that businesses and employers have found new and innovative ways to generate revenues to undertake improvements to the public realm, and to maintain first class services - particularly in respect of cleaning, security and policing, visitor management and infrastructure, and the management of new construction and development projects.
Local authorities are facing tough financial challenges. As a result, they are keen to embrace new models of service delivery and to work collaboratively with business partners to achieve this, including devolution. SBEG, SBBID and the wider business community are committed to this: our members are already putting significant resource into a range of services, and delivering them on a daily basis.
One example of this is an innovative arrangement with the London Eye, through a revenue-based Section 106 Agreement, which is administrated by a partnership between SBEG, local business representatives, and Lambeth Council. Revenue from the London Eye’s commercial activity directly funds a host of local services, including security and policing, cleaning, green space management, and the coordination of construction activity in one of London’s busiest neighbourhoods.
This is a significant commitment from business. The combination of the London Eye Section 106 Agreement, revenues that are paid through the SBBID levy and additional - and entirely voluntary - financial commitments that business and employers make to an array of South Bank services and projects exceeds £2m per annum. And these are ongoing commitments, made at a time when local government revenues and levels of public investment in South Bank are falling.
There is an increasing disparity between the level of business rates that are paid in South Bank, the additional commitments that business make to support local services, and the return that businesses receive from public bodies, including central and local government.
As such, not only is the 2017 Revaluation a serious threat to business viability, it’s also a very real threat to our members’ ability to continue to support the raft of essential services in South Bank, that help to make it an economically vibrant area. The potential disinvestment in local services - as businesses are forced to take difficult decisions over their costs - would be a disaster for South Bank, and for London as a whole, given South Bank’s preeminent position as a global hub for arts, culture and tourism.
Impact of 2017 Revaluation
All South Bank businesses are extremely concerned about the impact of the 2017 Revaluation, which will clearly hit South Bank hard. All business occupiers, across a range of sectors, will face substantial increases on their business rates. These include the operators of tourist attractions who have an inevitable focus on London and won’t see any “rebalancing” of their rates liability as they don’t have significant, if any, business operations elsewhere in the country. One South Bank operator is facing an increase in excess of £700,000 per annum. Another operator has a series of business premises in South Bank and elsewhere in Lambeth, and will face rate rises on all of these. As a borough, Lambeth faces an average rise of 35%, far higher than the average for London as a whole.
Similarly, a leading hotel brand who has invested significant sums of money in its London portfolio is set to pay, by 2021, nearly £12 million in business rates on its three South Bank hotels, irrespective of the level of transitional relief set under either option outlined in the consultation document. This has increased from £7 million on the basis of the 2010 rateable valuation.
A successful restaurateur who has invested in a range of new hospitality offers in South Bank and elsewhere in London, has warned of a “taxation Tsunami coming” and has commented that “with Brexit too, it’s got the potential to make for a series of capitulations in the hospitality industry.”
All of these businesses create jobs, drive investment and economic growth, and contribute significantly to the strength of London’s tourism and cultural offer which benefits other parts of the country. As a global economic force, what happens in South Bank has wider implications for Lambeth and Southwark, other parts of London, and the rest of the UK economy.
As highlighted in London’s joint submission, the rates system is one which penalises companies and employers in a number of ways, and is no longer reflective of how businesses work. Our members manage within tight financial margins. They can’t overhaul their operations to deliver higher returns to pay for such large increases in business rates, in the timescale that Government has outlined.
In addition to making redundancies, increasing charging and prices for customers (which isn’t commercially sustainable), the proposed increases will have a number of additional negative impacts, which are compounded by the fact that businesses haven’t seen a corresponding “return” in terms of investment and service delivery by public bodies. These impacts include the very real possibility that some businesses will withdraw their support towards neighbourhood services, to concentrate on their financial bottom line. Whilst this is understandable, the consequences for South Bank are extremely serious, as years of innovation and joint working would be undone.
Furthermore, the 2017 Revaluation poses considerable difficulties for Business Improvement Districts (BIDs) who raise revenues for local services through a levy on business rates. Any threat to the business community’s support for a BID will have serious consequences for local services that are currently funded through a BID and the revenue that it raises through its levy. SBBID has been operating for two years. It was set up to achieve many things, including helping to improve the management and maintenance of the South Bank neighbourhood in the face of ever-increasing footfall and falling Council investment.
SBBID currently funds a number of key services in South Bank, spanning security and policing, cleaning and graffiti removal, construction coordination and greening projects. SBBID also works to reinforce South Bank’s identify, reputation and brand. It invests and supports a range of marketing and promotional activity which drives South Bank’s success as the cultural heart of London, and its reputation as a leading destination for leisure tourists, business visitors and other audiences. SBBID currently raises nearly £500,000 per annum, and is due to re-ballot its members for renewal in 2019. Any threat to SBBID’s ability to raise revenues and invest in this way is potentially disastrous for South Bank’s economy and the services that the BID currently supports.
In line with the joint submission made on behalf of over 6,000 businesses in London, we ask that Government revises its transitional relief proposals to enable businesses to plan for any significant rate rises. We do not support either of the transitional relief options proposed in the consultation paper. This is for several reasons, including the fact that such large increases for those businesses with RVs in excess of £100,000, which are not mitigated effectively by either option, will slow investment, job creation and profitability for businesses at a time when confidence and stability are needed.
Furthermore, any transitional relief should enable businesses to plan and manage rate rises in a way which minimises surprises and enables business to invest for growth over the long term. Neither option 1 or 2 enables businesses to plan for growth, partly because the cap is set at such a high level, and also because the very significant changes in rateable values in places like South Bank is partly caused by the Government’s delay in implementing the revaluation process.
We asked that Government sets a lower cap on annual rises, for large businesses - which would be in line with previous revaluations. The joint submission outlines the ways in which this could be financed, to ensure that the transitional relief process remains revenue neutral.
We are clear as to the challenges that South Bank faces. The South Bank Manifesto 2014: A neighbourhood under pressure - prepared by SBP outlines the neighbourhood’s needs in terms of investment, infrastructure, and a quality environment. These ambitions will require significant levels of resource, and we are committed to finding new and innovative ways of securing this. We are keen to work with other central London BIDs on the feasibility of raising revenues through Tax Increment Financing (TIF) mechanisms to part-fund long overdue investment in public realm and infrastructure improvements in the South Bank and Waterloo area.
SBEG and SBBID submitted a joint response to DCLG on its recent consultation on Self-sufficient Local Government: 100% Business Rates Retention in which we acknowledged that fiscal devolution to the local level should provide incentives for growth, and pioneer new models of public service delivery. We expressed our disappointment that the consultation was so focused on the benefits, mechanisms and risks for local government, with very little consideration shown for what businesses and employers need, to ensure that growth can be encouraged and sustained, and for economic neighbourhoods to remain competitive and strong.
The 2017 Revaluation has demonstrated that the proposed retention of business rates at the local level shouldn’t be the preserve of a local authority, and we strongly recommend that business representatives, including Business Improvement Districts, are given a greater say in how policies and mechanisms are developed and implemented.
There is a strong rationale for business and employers reframing, funding and delivering local services, and the implementation of policies concerning the local retention of business rates is a critical factor in how this can be done. The 2017 Revaluation provides a further imperative to address this issue as an urgent priority.
I trust that these comments are helpful and constructive. I ask that they be read and considered in tandem with submissions made by SBBID and SBP, and the joint response from London’s business community. Together, they convey the strength of negative feeling regarding the Revaluation, and the options put forward by Government on transitional relief.
Please do contact me if you require further information, or clarification on any of the points raised.
South Bank Employers' Group