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03/10/2025

ASSC Responds to Consultation on Non-Domestic Rates Appeal Fees

The Association of Scotland’s Self-Caterers (ASSC) has submitted a detailed response to the Scottish Government consultation on the introduction of fees for appeals against non-domestic rating valuations.

The ASSC has made clear its opposition to the principle of charging businesses to challenge rateable valuations. The right to appeal is a fundamental safeguard within the system, ensuring fairness, transparency, and accountability. Introducing fees would risk deterring legitimate appeals, particularly from small and micro businesses already under significant financial strain, and could ultimately undermine access to justice.

In its response, the ASSC highlighted recent systemic failures, including the removal of many self-catering properties from the non-domestic rating roll in 2023/24 due to administrative and communication shortcomings. These events demonstrate why businesses must retain the right to challenge errors without the added burden of costs.

ASSC Chief Executive, Fiona Campbell MBE, commented:

“Appeal rights are a cornerstone of fairness in the non-domestic rating system. To impose fees would not only disadvantage Scotland’s small and family-run businesses, but also risk creating barriers to justice at a time when trust in the system must be rebuilt. We urge the Scottish Government to exercise caution and to prioritise evidence, fairness, and proportionality.”

While the ASSC’s primary position is clear opposition to the introduction of fees, the organisation has also set out fallback recommendations should Government proceed. These include:

  • Ensuring any system aligns with the UK framework for consistency
  • Keeping fees modest, proportionate, and accessible (e.g. £150/£300 tiered structure)
  • Providing clear refund and exemption provisions
  • Protecting community-run, charitable, and low rateable value properties
  • Conducting a full review of the new two-stage appeals process before any introduction of fees

The ASSC will continue to advocate for a fair and transparent non-domestic rates system that supports Scotland’s tourism businesses and strengthens the communities in which they operate.

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