submission Flashcards

1
Q

Talk me through your industrial comparable valuation in Canning town

What was the guidance note for comparable evidence

(Valuation L2)

A

RICS Guidance Note ‘Comparable Evidence in Real Estate Valuation’ 1st Edition, 2019

I valued an industrial unit occupied as a warehouse for rating maintenance purposes.

This was a newly built property therefore the rent agreed was significantly removed from AVD.

Utilising the comparable method I gathered rental evidence of similar properties in the locality and formed a basked of evidence.

After adjusting, and analysing each comparable rent to the term certain i weighted my evidence having regard to the hierarchy as well as the statutory definition of rateable value.

I applied good weight to my comparable items given they were agreed on FRI terms and in good proximity to AVD.

I was then able to form an opinion of value of the subject property and updated the rating list.

Plant and machinery? - power, heating, Movement, Structure
Car parking - 10 open surfaced spaces @ £300 per space

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2
Q

Talk me through you valuation of the library in Whitechapel

and what is the guidance note relating to this

(Valuation L2)

A

(UK Guidance Note) Depreciated Replacement Cost method of valuation for financial reporting, 1st Edition November 2018

I assisted in the valuation of a library in Whitechapel for rating purposes

Given the specialised nature of the property and the limited market evidence i utilised the DRC approach

Firstly I determined the Estimated Replacement cost of a modern equivalent and made adjustments for age and obsolescence using BCIS to come to an Adjusted Replacement Cost

It was 1960s building therefore i applied an adjustment of 60%

York museum case law

I then undertook market research of comparable evidence to calculate the land value and added this to the adjusted replacement cost.

lastly i applied the statutory de-capitalisation rate of 4.4% to come to an annual equivalent of capital value i.e rateable value

Flat roof - prone to leaks, cheaper to construct, more prone to repair.

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3
Q

What advice did you provide for your residential valuation in Royston

and what is the guidance note (professional statement) for Residual valuations

(Valuation L3)

A

(RICS Professional Statement) Valuation of Development Property October 2019.

I completed the valuation of a detached residential property in Royston for inheritance tax purposes.

The property was large and unmodernised and it had a significant plot of land attached. So for this reason i decided that there was development potential for a potential investor.

I completed market research to assess the Gross Development value of the site looking at what could be constructed and the completed value potential

looking at similar plots of land which had planning schemes approved, i determined that a further single detached property of a similar size could be constructed.

I used BCIS to calculate and deduct the costs for demolishing the existing structure and building two new properties on the land

as well as deducted associated costs of marketing, agents and professional fees, statutory costs and site prep.

As well as finance on a straight line basis assuming 100% debt compounded over the estimated length of development. I estimated a conservative length of 12 months at an interest rate of 5%

I also deducted a profit of 20% and made a contingency allowance of 2.5%

I lastly made a 15% deduction to the full development value in line with fifield v irc case given the risk that planning permission had not yet been granted.

following these deductions i was able to establish the land value which was in line with the value returned.

following approval, I then advised HMRC that the return value was reasonable and reported the case.

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4
Q

What advice did you provide for the retail unit in crouch hill

A

I completed the valuation of a retail unit in crouch hill for inheritance tax purposes.

The unit was occupied as a coffee shop and located on a high street within a parade of shops.

The shop was let as well as lease terms being provided so i used the investment method of valuation to calculate its capital value at the valuation date.

i completed research of rental evidence within the locality and determined that the property was let below market rent therefore i used the term and reversion method.

I completed market yield evidence to determine an appropriate yield and capitalised the rent to the next review.

I then capitalised the market rent at a revisionary yield (market rent/price) into perpetuity deferring the income by the length of the remaining term

Adding both the term and reversion together allowed me to calculate the capital value of the shop which was in line with the value returned.

Following approval from a registered valuer i then reported this to HMRC.

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5
Q

Talk me through the lease extension valuation in Brentwood

A

Under supervision, I completed the red book valuation of a 1 bedroom retirement flat in Brentwood for lease extension purposes.

I completed conflict of interest checks and ensured I was competent before issuing a terms of engagement to the client.

I inspected the property measuring to IPMS Residential 3B and noted its condition and value significant factors within my valuation template.

I used the comparable method to determine the market value on the long leasehold value of the subject.

Calculate the value of the existing freehold interest by:

Capitalising the ground rents receivable at 7% till lease expiry
and
deferring the freehold VP value at 5% for the length of the term (sportelli case law)

then Calculated the value of the landlords interest after the grant of a new lease by deferring the future interest for an added 90 years at 5% and took this off the value of the existing freehold value

to calculate the diminution of the freehold interest.

As the lease was under 80 years I calculated marriage value by:
adding together
Value of tenant’s future interest
Value of landlord’s future interest
less
Value of tenant’s current interest - using graphs of relativity
Value of landlord’s current interest

Then split this 50% to get the landlords share in marriage value
Added the diminution of the freehold interest to get he premium payable

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Capitalise ground rents receivable at 7% for the remaining number of years left on the lease (no ground rent on retirement flats)

Capitalise the reversionary Freehold long lease value at 5% deferring for initial length of the term

Less reversion to freehold vacant possession value capitalised at 5% and deferred for an extra 90 years

To work out the dimunition in value of the freehold interest.

MARRAIGE VALUE

Add together the freehold value and freeholders interest post lease extension to get the value of the combined interest.

less the value of flat with its existing lease from GOR and Freeholders interest pre extension to get the marriage value

then split 50/50 to get freeholders share and add this to the original diminution in freehold interest to work out the premium

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6
Q

Talk me though the valuation for the office in Millbank tower

A

I completed the valuation of a 4th floor office assessment in Westminster for rating purposes where I negotiated the withdrawal of a challenge.

The agent had submitted a challenge and sought a reduction in rateable contending the underlying rate was excessive and out of line with market rent

I used the comparable method of valuation to analyse, adjust and weight the subject and comparable rents within the building.

The rent on the subject was a rent review with a deed of variation attached whereby the rent was subsequently lowered significantly below market rent. - I therefore attached little weight to this evidence.

Adjusted and analysed rents within the subject building provided support for the adopted rate and existed as new lettings agreed close to AVD. - I attached good weight to this evidence and provided this within my initial response to the interested party who agreed to withdraw.

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7
Q

Talk me through the valuation for Leadenhall Market

A

I completed the valuation of a retail unit in central London for rating purposes using the comparable method where I agreed a revised rateable value.

The agent had submitted a challenge and sought a reduction in rateable contending the underlying rate was excessive and out of line with market rent

The subject rent was almost 2 years post AVD therefore I attached little weight to this evidence.

I then gathered, adjusted and analysed a basket of comparable rents in agreed as new lettings and in close proximity to AVD

These supported a revised rateable value in line with the passing rent was reasonable therefore an agreement was reached with the rating agent and the rating list was updated.

I also completed consequential valuations to those comparable properties in the basket who’s rents supported a revised underlying rate.

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8
Q

What advice did you provide for the retail unit in Knightsbridge

A

I valued a retail unit in Knightsbridge for non-domestic rating purposes using the comparable method of valuation to disagree a challenge proposal and maintain the 2017 rateable value.

The two contentions were that the RV was out of line with the rent passing and secondly that the unit should be valued as a car showroom in line with a use clause in the lease.

I advised the agent that the unit wouldn’t be considered in a different mode and category as we value vacant and to let use clauses do not run with the land i.e a shop is a shop but not any particular kind of shop as outlined in the fir mil case.

I also made reference to Section 2 Part 7 & 5a of the rating manual which details a list of examples of uses which could be considered as being in separate modes or categories. 5a details survey requirements for car showrooms i.e that measurements should be taken to GIA and that all car showrooms have a requirement for land to display cars for sale, customer and service parking, and car storage.

In regard to tone - identical units either side were agreed new lettings significantly closer to avd and provided support for the underlying rate adopted.

I therefore maintained the 2017 rateable value.

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9
Q

What advice did you provide for the retail unit in Mayfair

A

I dealt with a proposal to delete the retail unit from the rating list due to water damage.

After reviewing the photographs it was clear that the property was merely in a state of disrepair, with peeling wallpaper and damp to the walls and ceilings.

It was an objective fact that the subject was not undergoing a scheme of works nor incapable of beneficial occupation.

where Such works included full stripping out of the property, structural demolition, removal of internal wall and floor coverings etc.

therefore determined the repairing assumption would apply in this case.

and maintained that the hereditament should remain within the rating list

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10
Q

What advice did you provide for the Retail West Kensington

A

I received a proposal to split a corner high street retail unit into front and rear parts for non-domestic rating purposes.

It was also contended that the front should be valued as an office in line with its use as a solicitors.

Each was leased by a separate occupier, had separate entrances, had no form of intercommunication and satisfied the 4 components of rateable occupation therefore couldn’t be merged under PICO 2018.
I therefore split the unit into 2 separate hereditaments.

I also advised the ratepayer that the mode and category should remain as retail as we value vacant and to let and therefore on this basis would be valued as a shop in line with the rents commanded by the subject and comparable units in the parade.

Scottish and newcastle v williams - physical and use limb

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11
Q

Talk me through the part 1 claims in Milton Keynes

A

I assisted with several Part 1 claims under the Land Compensation Act 1973 relating to a smart motorway scheme in Milton Keynes.

The scheme involved adapting the hard shoulder to an open lane between Junctions 13 and 16 on the M1 motorway.

I undertook research for comparable properties, analysing sales evidence, and assessing environmental factors using National Highways reports.

Through site inspections and discussions with claimants, I determined there to be no deviation in comparable sale value or disturbances such as noise, environmental impact, and light pollution from the relevant day to the first claim date.

Consequently, I concluded no compensation was warranted and communicated this to a Registered Valuer colleague.

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12
Q

Talk me through the land cost estimate in Colchester

A

I assisted in providing a National Highways land cost estimate for the A12 road widening scheme from Junctions 11 to 28.

I utilised both internal and external land transaction databases to compile comparable sales evidence of various land types to produce a £/acre for each type, recording this within the master spreadsheet.

I then summarised value trends within each land type and reported this to a Registered Valuer.

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13
Q

Talk me through your residential valuation in Chingford

A

I undertook an IHT 50% undivided share valuation involving a residential property in London.

I adopted the comparable method of valuation and arrived at an entirety figure. The co-owner resided at the property, therefore having regard to appropriate case law, I applied a 15% share discount to the 50% value.

My valuation suggested the returned IHT figure to be too low therefore I entered into negotiations and presented my evidence to the Executor. A revised 50% share valuation was agreed, and I advised HMRC of this uplift.

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14
Q

Talk me through your mixed use valuation in Walthamstow

A

carried out an IHT valuation of a mixed-use freehold property in East London.

The property comprised a high street retail unit and a self-contained two-bedroom flat above.

I adopted the investment method of valuation collating rental and yield evidence within proximity to the valuation date.

Following appropriate adjustment and analysis, I ascertained the market rent was in line with passing rent.

I then capitalised the rent by a gross yield to arrive at a market value for the entire property.

I considered the concept of prudent lotting valuing each part separately.

It was confirmed the property had a higher value as two separate lots rather than as one. The returned value was in line with my valuation decision.

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15
Q

Talk me through your residential valuation in carsharlton

A

I was instructed to value a two storey semi-detached property in Carshalton for IHT purposes.

Following a desk-based review, utilising the comparable method, I determined the returned value to be too low.

I therefore inspected and measured the property to GIA, noting all value significant features.

On return I reviewed the evidence and attached weight to a sale on the subject street that occurred a few months before valuation date.

I was mindful the valuation date was shortly after the change in interest rates. I

advised client of my higher opinion of value who instructed me to negotiate.

I presented the evidence and how these had been adjusted and analysed. Following discussions, a revised IHT valuation was agreed which I reported to HMRC accordingly.

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16
Q

What advice did you provide for the mixed use property in Ilford

A

I provided the apportionment values for a mixed-used property in Ilford for CGT purposes.

I utilised the investment method to value the property as one

to which I then had regard to the apportionment values valuing each part separately

I used the comparable method of valuation to value the residential above and the investment method to value the ground floor office below.

which resulted in a higher value for the offices and a lower value for the residential part.

Entering into negotiations with the taxpayers representative I advised that a 10% allowance for the fact that the flat was ancillary to the offices would not be applicable as each part had their own separate entrance from the roadside and presented comparable evidence showing that the value was in line with comparable flats above retail and office accommodation.

I also advised that although the loft space accessed via an internally constructed staircase didn’t have building regulations approval nor nor planning permission for a living space, that I had adjusted for the fact that the property was a 1 bedroom flat with easily accessible loft room space taking into account the hope value that minor works could be completed to turn this into a 2 bedroom flat and significantly increase value.

Through negotiation a revised higher value for the flat and a lower value for the offices were agreed to which i reported these apportioned values to my client

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I provided the apportionment values for a mixed-used property in Ilford for CGT purposes.

I utilised the investment method to value the property as one - completing market rent and yield research determining the property was let at market rent and so capitalised the rent passing into perpituity at a suitable yield.

I then valued each part seperately adopting the comparable method for the residential part and the investment method for the retail part.

This resulted in a higher office value and lower residential value than what had been put foward therefore i entered into negotiations with the taxpayers representitive.

I advised that a 10% allowance would not be applicable in regard to the flat above being ancillary to the offices below given that both parts had separate access via two distinct doors from the street. I provided comparable evidence of similar properties where separate entrances existed showing no allowance had been granted for this consideration.

I also advised while the loft space didn’t have building regs approval nor nor planning permission for its current use as a living space, the alterations to construct in internal staircase up to the loft room did indeed add value. I advised that the property should be valued in its entirety i.e . as a one-bedroom flat with the added benefit of easily accessible loft space rather than a one bedroom flat only.

I also noted that the lack of building regulations could be overcome by replacing the current Velux window with a dormer and additional strengthening which would then allow it to be utilised as a second bedroom.

I made reference to comparable properties and applied an uplift regarding the added value of having easily accessible loft room space and the reasonable prospect of converting this space into a living space accounting for risk.

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17
Q

What advice did you provide in regard to the residential property in crouch hill

A

I provided the valuation for a residential terraced property in disrepair in crouch hill for IHT purposes.

I adopted the comparable method of valuation gathering transactions of properties in a similarly poor condition sold close to the valuation date and made appropriate adjustments based on the subjects condition.

I deemed the value returned to be too low and agreed an uplift returned figure.

I advised that the property was in a poor state of repair and after making relevant adjustments comparable evidence presented the value returned to be too low to which a revised return value was agreed and returned to HMRC.

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18
Q

What advice did you provide for the residential property in Beckenham

A

I provided the valuation of a detached residential property in Beckenham for IHT Purposes.

I advised that while there was no hope value for for redevelopment, using the comparable method, I determined the value returned was too low.

In gathering, adjusting and weighting a basket of comparable evidence I was able to agree a revised uplifted return value and reported this to HMRC.

The property was unmodernised and on a large corner plot of approximately 0.13 hectares.

I considered hope value could be possible for the development of a second dwelling.

My findings established the property was in a conservation area and so any further development was limited. Furthermore, my investigations confirmed a number of planning applications for extensive large scale redevelopment had been declined to preserve the locations character.

I gathered comparable evidence of similar detached unmodernised houses, which I adjusted and analysed and reported an agreed revised value to HMRC.

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19
Q

Talk me through your inspection in Stamford Hill

A

I inspected a terraced house for IHT purposes

firstly I completed health and safety procedures and and adhered to the VOA lone worker policy - diary, manager, skyguard, PPE

I then undertook an inspection of the local area noting amenities such as transport links, shopping and leisure facilities, green areas, and comparable properties.

I then externally inspected the property noting age, location condition, construction

before internally inspecting the property measuring to GIA and taking photographs and noting internal condition, bedrooms, bathrooms, modernity etc.

Located on a no through road less traffic quieter. - reasonable state of repair.

I then concluded my inspection returning to the office and saving my documents on a secure file.

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20
Q

Talk me through your inspection in tower hamlets for the retail premises.

A

I inspected a three story retail unit occupied as a salon and premises for rating purposes.

firstly I completed health and safety procedures and and adhered to the VOA lone worker policy - planning my route, diary, manager, skyguard, PPE

I then undertook an inspection of the local area noting trade, transport and comparable properties.

I then externally inspected the property noting age, location condition, construction at each level

before internally inspecting the property measuring to NIA noting fit out, air conditioning, and other value significant features.

I then concluded my inspection returning to the office and saving my documents on a secure file.

Zoned 6.1 - no RF - full air conditioning, wall mounted fan coil.

fan coil, comfort cooling, static cooling, variable air volume, variable refrigerant volume.

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21
Q

what advice did you provide for your inspection at the strand office

A

I completed the inspection of a 3 story office assessment in Westminster for rating purposes

The property has been recently refurbished however I advised that the property was not indicative of category A fitout therefore an uplift in value for fit out should not be applied.

Grade A would have

State of the art it infrastructure
Triple glazing
high efficiency air conditioning, heating and ventilation
sustainable building features
High quality design and materials
full access raised floors w/floor boxes
excellent natural lighting

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22
Q

What advice did you provide for your inspection at the industrial in Stratford

A

I completed the inspection of a warehouse for rating purposes.

The property had a basic fit out with an ancillary office found on a mezzanine floor.

I measured to GIA noting
Eaves Height
floor loading capacity
construction
site area
plant and machinery
and car parking

After noting 10 car parking spaces directly assigned to the subject, I advised these should be included within the survey.

£400 per space in line with subject and comparable evidence

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23
Q

What advice did you provide for your inspection for the residential property in Muswell hill

A

I inspected a semi detached residential property for inheritance tax purposes.

I advised that the internal condition and state of repair was poor due to a number of wall cracking to the ground floor as well as rising damp in corners of the property.

I advised that after gathering comparable evidence of similarly poor properties that the return value was acceptable.

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24
Q

Talk me through the measurement of the barristers chambers office in Westminster

A

I have measured a barrister’s chambers for rating
purposes. I measured the property to Net Internal Area
(NIA). On return I produced a digital plan and calculated
the relevant areas.

25
Q

Talk me through your stamp duty land tax measurement

A

I used a digital mapping software to measure agricultural and development land for stamp duty land tax purposes.

I measured the land in hectares noting its use (paddock, pasture or arable land) greenfield/brownfield, flooding risk planning permission and whether the transactions were at arms length.

To which I noted in the master spreadsheet for valuer’s to use for comparable evidence

26
Q

Talk me through the measurement of the retail unit in Leyton

A

I completed the inspection and measurement of a retail unit in Leyton occupied as a barbers for rating purposes.

I measured to NIA (Zoned 6.1) and sketched a floor plan discounting all excluded areas in line with the code of measuring practice.

27
Q

Tell me about how you managed the data for the office in Liverpool street

A

I dealt with a challenge proposal for rating purposes where the agent had requested a copy of form of return details used within my basket of evidence.

Given the sensitive nature of the data, I made arrangements to meet with the agent face to face advising them that they could not make copies or take photos of the data presented

28
Q

Tell me about how you managed your data on the ministry of justice assets project

A

My role involved searching external
databases to gather land transaction evidence for 18
courts in South-East England. I assembled my evidence
into a Microsoft excel spreadsheet, adjusting and
analysing the evidence. I advised the lead valuer
highlighting the use, location, and size of each land piece,
as well as planning permission documents on submitted
and/or approved schemes.

Managed data on a secure password protected drive

29
Q

What typical defects would be associated from a 18th Century building.

A

Damp/property movement defects/ ageing & wear and tear due to lack of maintenance

30
Q

Was this a listed buildings ? What impact would this have on the valuation if it was ?

A

Not a listed building but (maybe higher value due to historic nature & individuality, character) BUT Could also come with higher maintenance + restrictions to works can be carried out + higher insurance costs + higher energy costs?

31
Q

Why is the kitchen spaces valued less than the restaurant?

A

main value is within the seating area

32
Q
A
33
Q

How did you check this challenge was complete and lawful?

A

Complied with the non-domestic rating regulations for list alterations and appeals 2017

34
Q

Was the subject rent for a shell unit? What other fit out states can you let a property at?

A

Subject rent was for a cat b fitted out unit - cat A is shell and core

35
Q

Why did you not reflect the £600k? fit out. Are you aware of any cases relating to restaurant fit out?

A

I did not reflect the fit out costs as these were confirmed by the agent to be non rateable items as well as the comparable evidence to be relied on - Masala v Golding case law on restaurant fit out

36
Q

Why did you not consider increasing the £/m2? Two best weighted evidence is around £1,250?

A

standing back and looking at the rental evidence and settlement evidence I considered the tone applied to be fair and reasonable given the settlements in Chandos place which I considered a comparable location

37
Q

You mentioned about establishing a tone? What are the different stages of tone of the list?

A

(O’brien v Harwood 2003) start of the list where entries are untested

  • Overtime assessments will be challenged/agreed/disagreed -

final stage where enough settlements have been determined to establish a pattern and tone of the list (confirmed in futures v stratford)

38
Q

Why did you include the toilets in your NIA?

A

comp for rating customer toilets included

39
Q

If the agent disagreed with the outcome how long do they have to appeal the Challenge?

A

4 months

40
Q

Retail Knightsbridge
You stated the agent had two grounds of appeal – was this on the same challenge? Can they have two grounds in the same challenge? what were the two grounds?

A

Mistake in wording - one ground of appeal as a compiled list challenge however there were two contentions involved i.e if complied list challenge effective and material date would both be 1/4/17 but If MCC date of check submission

41
Q

What do you understand by the term mode and category?

A

a property can only be considered within it original mode and category of use as it existed on the material day only minor alterations can be considered

42
Q

What key case law discuss this issue? What was the outcome of the decision?

A

Valued as wine bar/pub in line with use - scottish and newcastle v williams

43
Q

Retail Mayfair
Dealt with a proposal relating to water damage, you decided the property was simply in disrepair how did you determine this?

A

the repair assumption applies if the works are economic to put the building back into repair

44
Q

What was the key case that discussed disrepair?

A

canary wharf v jackson or Princess street case? Economical repair - landlord would look at the market, length of lease, location to determine whether costs are reasonable and over what period they would be prepared to spread repair costs

45
Q

What were the three questions to consider?

A

is the headitament in a reasonable state of repair - if not can the works required to do so be described as repair - would a reasonable landlord consider the repairs economic

46
Q

Retail West Kensington
You stated that you were satisfied that there was no intercommunication between the two parts and therefore agreed to split? does there need to be intercommunication?

A

no need for intercommunication for merge just Pico act

47
Q

What case preceeded the property in common occupation Act 2018 ?

A

Mazars v woolway - passing through common space to get from one part to another would be considered separate - reversed in pico

48
Q

Retail Market Leadenhall
You attached low weight to the subject rent two years post AVD? which case law informs us to do this?

A

Specialeyes v Felgate - LESS WEIGHT POST AVD

49
Q

If an agreement is reached can the agent still decide to appeal the case to the tribunal after?

A

No agreement is binding in agreement and settlement

50
Q

Level 1
You state you aware of exemptions and reliefs – Name me 4 different exemptions

A

LGFA 1988 S5 P9 - FISH FARMS, PARKS, AGRIGCULTURAL, DOMESTIC

51
Q

Name me the new relief that has come into effect this year? How does it work? Which legislation brought this into effect?

A

Improvement relief - non domestic rating act 2023

You might get improvement relief if you make certain improvements to your property. If you’re eligible, you’ll get the relief for one year. It starts from when you complete your improvements.

Eligibility
Any improvements you make must:

increase the ‘rateable value’ of your property

be completed on or after 1 April 2024

They must also either:

increase the size of your property

add new features or equipment to your property, such as heating, air conditioning or CCTV

Any improvements to existing features or equipment do not qualify.

52
Q

What is a Transitional Relief ? When is it appropriate ?

A

Tapering of RV between rating lists - when one list cannot be amended

53
Q

Data Management
For your Stamp Duty Land Tax analysis how did you manipulate and organise the data?

A

Input data, highlighted trends, created filters for different land types and uses.

54
Q

How did you ensure the data was protected?

A

permissions protected on a password protected device w/ firewall

55
Q

What advise on data management did you give to your registered valuer?

A

advised on the use, hope value, floodrisk, planning permission + highlighted trends within the data

56
Q

For your FOR viewing with the agent – why can the agent not take photographs but can make notes on it?

A

Given the sensitive nature of the data I was able to read out the relevant information while redacting non relevant sensitive information

57
Q

What if the agent requested to see additional rents outside of what you provided him?

A

Only if they were relevant to the statutory duty I was carrying out

58
Q

What does CRCA mean

A

CRCA means that all information held by the VOA is covered by the duty of confidentiality and it specifies the circumstances when information can be disclosed.

59
Q

Can you tell me what you did in the Land Cost Estimate.

A

I identified the land to be acquired and the potential costs involved for the client. This included land acquired, severance and injurious affection, disturbance, and fees. I researched planning consents and allocations for the areas concerned to identify and advise on any risks, and associated costs. I collated the data onto a spreadsheet for ease of management and advised my colleague of the valuations to be included in the report to the client.