Consultation outcome

Digitalising Business Rates: connecting business rates and tax data – summary of responses

Updated 15 March 2023

Foreword

Digitalising Business Rates, first announced by the government in 2016, is an exciting opportunity to modernise the business rates system and make it fit for the 21st century. The programme will provide the opportunity for greater precision and flexibility in policy making by linking HMRC business data with property data currently held by Billing Authorities.

Currently, the government does not have a clear picture of how commercial property occupation relates to businesses. Business rates policy is therefore wholly targeted by property use or value, rather than any business characteristics such as profit or turnover. Digitalising Business Rates will therefore enable us to explore new policy options, which consider wider business characteristics, such as more efficient and better targeted reliefs to support businesses.

Digitalising Business Rates also has the potential to help local authorities tackle avoidance and evasion more effectively. Whilst the current system often relies on unvalidated ratepayer self-declarations when determining relief eligibility, Digitalising Business Rates will allow Billing Authorities to check, for example, that ratepayers claiming Small Business Rate Relief are not breaching the qualifying criteria by occupying multiple properties in other areas using improved centralised data.

This consultation has been vital in ensuring the views of stakeholders are reflected in the programme’s design and penalty regime, and I would like to express my sincere thanks to the wide variety of organisations and individuals who have taken the time to engage with us.

In response to the consultation responses received, the government has decided to focus for now on the central data-matching aspect of Digitalising Business Rates, without initially providing a platform for ratepayers to see their tax and business rates information together. Getting this core data-matching right will deliver the key benefits stakeholders were most invested in during the consultation, and leave the door open for further potential reforms in future.

This consultation response constitutes the final document to be published by the government on Digitalising Business Rates before we take forwards legislation. The government will continue to engage with stakeholders as the programme continues to be designed and implemented.

Victoria Atkins
Financial Secretary to HM Treasury

1. Executive Summary

1.1. Digitalising Business Rates (DBR) was committed to by the government in 2016. A consultation was published in July 2022 and ran until September 2022. We would like to thank all our stakeholders for the time and effort in engaging with the consultation process and their invaluable feedback.

1.2. DBR is looking to link business rates information (held by local authorities responsible for business rates billing and collection – Billing Authorities (BAs) to tax records (held by HMRC). This will provide central and local government with new and richer data, based on a more holistic view of a business ^{[footnote 1]}. This will enable government to provide better targeted support to the businesses who need it most and improve business rates compliance (for example help BAs to prevent abuse of Small Business Rates Relief).

1.3. The government consulted on which tax or property reference numbers should be used to match business rates and tax data, how they should be collected, and how that matched data could then be shared with BAs and other government departments to improve services and policy decisions. It also contained questions around how the system should operate, including a compliance regime and access by agents.

Stakeholders responded to the consultation with a range of views. In summary:

1.4. Regarding the scope of DBR there were mixed feelings, with some welcoming the limited scope while others felt it could go further to provide more value for ratepayers.

1.5. Most respondents favoured providing a tax reference number rather than a property reference for the matching as it was easier to locate. Those who suggested a property reference number had differing views on which property reference number would be best to supply.

1.6. Most respondents also felt collecting a tax reference as part of the new Valuation Office Agency (VOA) duty (option A) was the best option as it offered the easiest customer journey.

1.7. Respondents welcomed the overarching design principles around customer experience set out in the consultation and identified the ability for the government to better target support as a key benefit.

1.8. Some stated that although having the centralised billing functionality would be a ‘nice to have’, the main benefit and value as a user would be the ability to also make bill payments through the same service, otherwise it would be duplicating information they already have access to.

1.9. There were mixed views about penalties being used overall for DBR, as some felt it was not proportionate. Most respondents answered that if we were proceeding with penalties for data-in option A, there should be a single regime for both DBR and the VOA duty.

The government has deliberated on the views of stakeholders and responded to the consultation. In summary:

1.10. After considering stakeholder feedback and early user testing, alongside the costs and wider capacity constraints, we do not believe that building a service to display billing and tax information in one place represents good value for money and nor would it be the best use of taxpayer resources at this time. Therefore, the government has decided to descope this element from the project, which will instead focus on delivering the core matching capability, supported by collecting a tax reference number from ratepayers. This will lay the foundations for a gradual development of the DBR system in the longer term, subject to future decisions to add on additional services.

1.11. The government will capture the information required for matching alongside the new VOA duty (option A), as stakeholder feedback suggested this would be the most simple and seamless user journey. The system will be designed to capture a tax reference (and accompanying information where needed to validate that tax reference) through an integrated journey with the new VOA duty, so ratepayers can use a single portal for all their business rates interactions with central government.

1.12. As set out in the consultation document, in order to obtain the expected benefits of DBR, the government requires accurate data matching. This requires creating a new obligation for ratepayers to provide reference numbers, with an accompanying sanctions regime for non-compliance. However, the government will design the sanctions regime in a manner which, in the first instance, encourages and supports ratepayers to satisfy their DBR obligation – issuing penalties will be the last resort where other compliance actions have failed.

2. Introduction

Details of the consultation

2.1. The DBR consultation was published on 20 July 2022 and ran until 30 September 2022.

2.2. The consultation set out options to deliver the commitment to modernise and digitalise the business rates system through the DBR project by matching business rates data held by BAs with central HMRC tax data.

Overview of responses

2.3. In total HMRC received 62 written responses (via the survey and email) to the consultation. Of these 14 were from individuals, companies, and not-for-profit organisations, 9 from agents, 19 from BAs or local government groups and 20 from representative bodies (who represent over 175,000 members including ratepayers and their agents). A list of respondents to the consultation, excluding individuals, can be found in the Annex.

2.4. HMRC also provided other opportunities for stakeholders to express their views. During the consultation period, HMRC held 4 livestreams (live online sessions introducing DBR) and 13 roundtable discussions, with over 200 attendees in total.

2.5. Overall views and general comments:

• the general tone of responses was positive, with respondents welcoming the fact that the government was consulting on the design at an early stage, giving stakeholders a chance to influence, contribute and prepare

• there was general support for the proposed scope of DBR, but stakeholders saw little value in being able to see their business rates billing information alongside their HMRC tax information (although some respondents suggested extending the scope to include payment of bills, for ratepayers to see the full value of DBR)

• most respondents stated they would be able to provide a tax reference number with relative ease, and many suggested having the option to choose the most applicable tax reference to provide

• regarding property reference, there were mixed views of which reference would be best, with most stating the BA reference number as most suitable

• most respondents chose option A (72%), which was to use the new VOA information duty process to collect a tax reference number, as they suggested it provides the simplest journey, minimising additional burden upon ratepayers

• respondents understood the need for a sanctions regime to manage compliance, but were clear that if option A was to be chosen then a single regime would be best so as to not penalise ratepayers twice for what will feel like a single process

Structure of the response document

2.6. This document is presented in the following further chapters:

• government response
• a summary of responses received from stakeholders laid out in the following sections:
  • DBR and the devolved nations
  • DBR design and data matching
  • receiving relevant business rates ‘data in’ to HMRC
  • data out from HMRC
  • compliance regime
  • other considerations
• next steps
• annex

3. Government response

Response to chapter 2 of the consultation: devolution

3.1. The scope of DBR is being extended to cover Wales as well as England. The UK government is working with the Welsh government on how DBR will be implemented in Wales.

Response to chapter 3 of the consultation: reference number

3.2. The government will seek to design an integrated service which allows ratepayers to provide the information that will be required by the new VOA duty and their tax information required by DBR at the same time, through a single service on gov.uk (see response to chapter 4 for more detail).

3.3. The government will introduce a new duty on ratepayers to provide a tax reference for DBR data matching, and to keep this number up to date where their circumstances change (in practice, where possible, most relevant changes should be picked up automatically, minimising the action ratepayers might need to take themselves).

3.4. The government proposes to accept the following tax reference numbers for the purposes of DBR:

• Self-Assessment Unique Tax Reference
• Partnership Unique Tax Reference
• Corporation Tax Unique Tax Reference
• VAT Registration Number
• National Insurance Number

Following stakeholder feedback, the government is confident that almost all ratepayers should be able to provide at least one of these numbers. However, as part of detailed design work, we will take into consideration those ratepayers who may not have a relevant tax reference number. The details provided by stakeholders on the circumstances where this could occur will be used to help design the processes. The government will also have the power to update the list of acceptable tax reference numbers in the future, should this be necessary.

3.5. As requested by stakeholders, the government is exploring building the system to give ratepayers flexibility to choose the tax reference number they wish to provide from the list set out above, to ensure an easy customer journey. Once detailed designs have been completed, the government will provide additional guidance for those with complex cases on how to fulfil the new obligation.

Response to chapter 4 of the consultation: data in

3.6. Taking into consideration feedback from the consultation, the government is looking to adopt a simple process to capture the necessary tax reference(s) required to match data for DBR, seeking to minimise any additional burden on ratepayers where possible.

3.7. There was overwhelming support for option A (collecting tax references through the new VOA duty), as it was seen by respondents as the simplest and least burdensome option for ratepayers. Having considered the views from all stakeholders, the government has concluded that the simplest and most streamlined way to collect the necessary tax reference for DBR is to do so through a single business rates service on gov.uk alongside the information required by the new VOA duty. This will provide the best customer journey for ratepayers by prompting them to provide a tax reference for DBR when they go online to comply with the VOA duty. It will allow ratepayers to manage all their business rates related interactions with central government in one place.

3.8. HMRC and the VOA will work closely together to ensure the design of the service results in a smooth customer journey, so ratepayers can fulfil both new obligations quickly and easily.

3.9. Work will continue to quantify any New Burdens funding (costs incurred by BAs as result of implementing the changes required by DBR) required. This will become clearer as the detailed design of DBR develops.

Response to chapter 5 of the consultation: data out

3.10. We have taken into consideration responses from stakeholders regarding the viewing of business rates information alongside tax information, together with more detailed feedback from early user testing and round table discussions. Although there was some support for this, accompanying discussions indicated it would be more of a ‘nice to have’ with limited benefits and some respondents felt that it would only be useful if bill payments could also be made. Given that building such a service would add significant cost and complexity to DBR, the government has concluded that it would not represent good value for money to proceed with this element of DBR at this time. Therefore, the government has decided to remove this element from the scope of DBR and will instead focus on delivering the core matching capability, supported by collecting a reference number from ratepayers to enable higher quality matching. This will lay the foundations for potential future expansion of DBR and will help reduce the potential risk of introducing several elements at once.

3.11. Through DBR, the government intends to share data with BAs to help improve decision making and compliance work. The administration of business rates will remain with BAs, including the operation of reliefs.

Response to chapter 6 of the consultation: penalties

3.12. As the government will be creating a legal obligation for ratepayers to provide and keep updated a tax reference number, there has to be a potential sanction for ratepayers who fail to comply, in order to encourage compliance. This is important because to achieve the desired outcomes of DBR – that is, to support application of reliefs where feasible and enable better targeted support to ratepayers and businesses when needed – DBR will need all properties relating to a ratepayer to be linked to their tax information. To do this, a high degree of confidence in the matched data is required to reassure customers their data is safe.

3.13. The government has considered the alternatives suggested by consultees but cannot be confident that these would provide a sufficiently comprehensive incentive (across all ratepayers) to ensure that DBR objectives can be met and is mindful of other consultees’ concerns that some alternatives could feel more disproportionate to certain ratepayers. Therefore, the government intends to take a power to allow it to penalise ratepayers who fail to provide a reference number required under DBR.

3.14. However, issuing penalties will be a last resort, and with the sole aim of ensuring that ratepayers meet their obligation. Therefore, to ensure that penalties are not applied and enforced disproportionately, and as requested in some cases by stakeholders, the government intends:

• that penalties are not initially levied when the new obligation comes into effect – instead, ratepayers will have a period of time to familiarise themselves with the new system before a penalty regime is implemented

• to use communications, reminder messages and nudges as far as possible to encourage compliance before issuing penalties

• for any ratepayer facing the possibility of a penalty to receive a warning letter first, providing them a further penalty-free period of at least 30 days before a penalty is issued

• that the legislation protects ratepayers by setting out maximum penalty amounts (see proposals below) and minimum time periods for compliance, but the government has discretion to apply lower amounts or longer periods, whether to all ratepayers, or ratepayers with certain characteristics or behaviour

• to ensure flexibility in the system to allow due regard to be paid to individual circumstance, for example ratepayers will be able to request to extend the timescales if they need more time to meet their obligation where there is a compelling reason

• that anyone who has been issued with a penalty has a fair opportunity to appeal the decision – standard HMRC review and appeals principles will apply for this purpose, including the ability to request consideration of a ‘reasonable excuse’ for non-compliance; tribunal appeals will be heard by the Valuation Tribunal

3.15. The government has considered the fact that most respondents indicated a preference for DBR to be included in the sanctions regime for the VOA’s new duty, rather than being subject to a separate sanctions regime. However, the government’s view is that, since the duties will be created as separate legal obligations – which may arise in different ways and at different times, and which will be owed to different entities (HMRC and VOA) – it is right, and legally appropriate, that the sanctions regimes for each duty also remain separate. This also means that each regime can be designed in a manner which reflects the specific nature of each duty; and it will avoid scenarios in which ratepayers may avoid all sanctions even if they only partially fulfil their obligations.

3.16. However, the government recognises that, because it intends to build an integrated service allowing ratepayers to fulfil their VOA and DBR obligations at the same time (where they arise at the same time), it will be important to ensure ratepayers are not disproportionately penalised by the 2 regimes. Therefore, in addition to the points listed in paragraph 3.15, the government proposes that in circumstances where the VOA and DBR duties arise at the same time, and are to be discharged by a ratepayer through the same online ‘journey’, a ratepayer will not be penalised twice even if they fail to comply with both duties. In such circumstances, the government will use discretionary powers to disapply a DBR penalty where a person is already subject to a VOA penalty.

3.17. The government plans to base DBR penalties on established HMRC penalties regimes. Legislation will allow it to charge an initial penalty of £100 for a failure to provide information, and penalties of up to £60 per day, after a further grace period of at least 30 days, for ongoing non-compliance. To protect ratepayers, the maximum amount chargeable under daily penalties will be capped at £1,800. Where false information is provided deliberately or carelessly, the maximum penalty will be £3,000. However, per above, the amounts charged could be lower if the government considered this more proportionate at the time or in the circumstances.

3.18. The table below summarises our proposed approach to the application of penalties, as well as outlining the customer journey:

Customer journey	Application of penalties – proposed approach
Before the penalty regime commences	Ratepayers will have time to familiarise themselves with the new system during a ‘soft launch’ before the penalty full regime is implemented. HMRC will undertake extensive communications, so ratepayers are aware of their new obligation. Communication by HMRC to ratepayers will clearly state any deadlines in providing the tax reference number.
Tax reference number information notice	After the ‘soft launch’ period has ended, if a ratepayer doesn’t provide a tax reference number by the required date or within the required time frames, HMRC will issue an information notice to ask the ratepayer to provide their relevant tax reference number through the service on GOV.UK. The ratepayer will have at least 30 days to provide this number, or to contact HMRC to ask for an extension, before HMRC charges an initial penalty. Ratepayers will be able to request more time if needed to meet their obligation where there is a compelling reason.
Initial penalty issued	If the ratepayer still fails to provide the necessary tax reference number after the deadline set out in the information notice, an initial penalty of £100 will be issued.
Appeal period	Ratepayers will then be given a further 30 days to comply or appeal the initial penalty.
Daily penalties issued	If the ratepayer still does not comply, a daily penalty of up to £60 can be issued up to a maximum of £1,800.
False information	Where false information is provided deliberately or carelessly by a ratepayer, a penalty up to £3,000 will be issued. This may be lower if it is considered more proportionate at the time or in the circumstances.
Interaction between VOA and DBR penalties	Where a ratepayer’s VOA and DBR duties arise at the same time, a ratepayer will not be penalised twice if they fail to comply with both duties. In such circumstances, discretionary powers will be used to disapply a DBR penalty where already subject to a VOA penalty.

Response to chapter 7 of the consultation: other considerations

3.18. The government welcomes feedback from stakeholders regarding agents’ access to the DBR system. We recognise that some businesses will benefit from agents helping them to meet their obligations. We will continue to consider the needs of agents as HMRC work with the VOA to design the new service.

Impact on ratepayers

3.19. The estimated impact of the new obligation to provide a tax reference number on ratepayers has also been considered. This analysis is outlined in the Digitalising Business Rates Impact Note which has been published alongside this Summary of Responses.

4. Summary of responses

This is not intended to be a comprehensive account of all points of view expressed in the submissions received, and instead provides a summary of commonly expressed perspectives.

4.1. DBR and the devolved nations

4.1.1. Chapter 2 of the consultation sought stakeholders’ views on extending the DBR project to Wales.

Question 1: How would Welsh local authorities, ratepayers, agents, and broader stakeholders feel about the possibility of DBR being extended to Wales?

How people responded

4.1.2. 37% of respondents answered this question. Of these, 78% were supportive of the possibility of DBR being extended to Wales, 17% were neutral and 4% objected.

4.1.3. Most of those who responded to the question felt that harmonisation and consistency of approach is preferable as it would minimise the burden for businesses that operate in both countries.

4.2. DBR design and data matching

4.2.1. Chapter 3 of the consultation described the elements of DBR design including how DBR may collect relevant business identifiers in order to confidently match business rates data to tax data in the simplest way, ensuring customers are not asked for the same information more than once. The chapter explained ‘what’ might be required from ratepayers and ‘why’ and sought to understand any scenarios where meeting this new requirement might be difficult.

Question 2: Do ratepayers know/can they find their Self-Assessment (SA)/Partnership/Corporation Tax (CT) Unique Tax Reference (UTR) and VAT Registration Number (VRN)? If not, what would make this easier?

How people responded

4.2.2. 48% of people responded to this question and of those, 83% agreed ratepayers would know, or could find, their SA/Partnership/CT UTR or VRN. Respondents thought that the service should be designed so the user has the option to decide which tax reference number is best/most appropriate for them.

4.2.3. A small number of stakeholders also felt it would be beneficial if a UTR could be retrieved via a look-up service by completing additional security checks.

4.2.4. Stakeholders welcomed DBR’s design principle of minimising ratepayer burden as much as possible, such as exploring whether information can be captured ‘behind the scenes’ without a requirement on ratepayers to provide a reference number.

4.2.5. Businesses with larger property portfolios felt any system to collect reference number(s) should not place undue burdens on ratepayers, be it time, resource, or cost, and it should not be onerous for ratepayers that occupy multiple properties. Respondents suggested that the service should have the ability to upload reference numbers in bulk.

4.2.6. Some BAs stated as part of administering coronavirus (COVID-19) business grants they asked ratepayers to provide a tax reference number, and whilst the information wasn’t verified most ratepayers did provide the information. This shows that there is a precedent for ratepayers being asked for and providing a tax reference number as part of their interactions with the business rates system.

Question 3: Where ratepayers do not have one of these relevant reference numbers, would identifying themselves as a taxpayer by providing a National Insurance Number (NINO) or Company Reference Number (CRN) cause any issues? If so, what are they?

How people responded

4.2.7. Just over half of respondents answered this question, of which 60% agreed that for a small number of ratepayers that do not have a tax reference number, identifying themselves by providing a NINO or a CRN would not be too difficult.

Question 4: If ratepayers alternatively needed to locate and provide property reference numbers, would it be easier for them to provide a) a BA reference number plus BA name or 4-digit BA code, or b) a Unique Property Reference Number (UPRN)?

How people responded

4.2.8. Most respondents (71%) answered this question, of which around half stated the BA reference and BA name was their preferred property reference number. BAs stated that the BA reference was on their bills and could be found on the VOA website, however noted that a BA code/name would be required to make it unique.

4.2.9. About a third of respondents who answered the question suggested a UPRN would be the best property reference to use. Those who suggested this stated that it was because it is a unique reference that could be matched on different systems, whereas the BA reference number may not be displayed in the same way across different BAs and there is the possibility of duplication.

4.2.10. A representative body and an agent noted that Unique Address Reference Number (UARN) (a unique identifier created by VOA) is currently used by ratepayers and agents for the Check, Challenge and Appeal (CCA) process and is an already agreed standard that works, so may be more appropriate.

Question 5: Are there scenarios where ratepayers might not have any relevant reference number? Including any scenarios where a ratepayer may not be registered for tax purposes? If so, what are they?

How people responded

4.2.11. Respondents felt that the majority of complex scenarios were set out in the consultation, but some gave some additional helpful details on other potential scenarios, which the government has divided into 2 categories:

Category 1. Cases that may not be able to provide the reference numbers required for data to be matched:

• new property not yet valued by VOA (awaiting property reference)
• company in administration or liquidation (request a new temporary UTR)
• non-taxable entities such as schools, universities, hospitals, and charities

Category 2. Cases mentioned by stakeholders which the government believes will require further consideration:

• buildings with multiple occupancy where rates are included in the rent
• those with secure customer records that cannot access online services (for example, government employees)
• offshore companies and trusts (and trustees)
• estates of deceased persons valued at less than £2.5m with income/gains below £10,000 adopting informal reporting arrangements
• exempt hereditaments including agricultural land and buildings (no business rates data to match to tax data)

Question 6: Are there scenarios where a person or entity’s identity in the tax system (with one tax reference number) may not precisely align with their legal responsibility as a ratepayer? For example, where multiple ratepayers share the same tax reference number, or multiple entities for tax purposes share one responsible legal identity in a business rates context?

How people responded

4.2.12. The consultation gave examples of when a person or entity in the tax system may not align with their legal responsibility as a ratepayer but also asked for any other scenarios stakeholders could refer to. The following examples and scenarios were given by respondents:

• where office space is let under licence which stipulates that the landlord will pay the rates, serviced offices and different lease agreements can change who is liable for rates; holding companies who sublet letting to their subordinate (sometimes multiple)
• sometimes with trading companies it can be hard to ascertain who has the ‘beneficial’ occupation
• some retail properties are occupied by 2 or 3 entities/liable parties, but as both share the space the VOA do not split the assessment
• subsidiary companies may be responsible for the business rates (for example, universities)
• joint and several liability (could be partnerships or companies)
• multiple entities for tax purposes could share one responsible entity in a business rates context as regards to group company arrangements
• when a business ceases or goes out of business
• a single lease might cover a number of hereditaments

4.2.13. Some particular issues where a tax identity may not precisely align to a legal responsibility as a ratepayer were highlighted by respondents:

• liability for business rates is based on occupation of a property or, in the case of empty properties, based on ownership, which is not the same for other business taxes such as VAT or Corporation Tax (for example, all persons who have an equal interest in the property are jointly and severally liable and that this may not be the same for an entity such as a limited company), therefore, the link between them may not always serve the purpose of DBR

• issues could arise with jointly held properties, where for example only one of the joint owners is responsible for paying the business rates, but all owners would record their share of taxable income arising from renting out the property

4.2.14. Most stakeholders felt many of these complexities could be overcome by having a user-friendly system and appropriate mechanisms for support.

Question 7: When might a taxpayer reference that is associated with a property portfolio under DBR change (for example, registration for self-assessment, incorporation or disincorporation, VAT-registration, or de-registration, mergers, and acquisitions)? Are there scenarios where the new reference number might not precisely assume the property portfolio associated with the previous number?

How people responded

4.2.15. Respondents stated that at times a group of businesses will allocate different businesses (within the group) as being responsible for business rates on a property because of internal arrangements they have made to make payment. So, if a property is linked to a specific tax reference, this could change throughout the year, and the new business (if they possess a different tax reference number) will need to claim the property under their tax reference.

4.2.16. The rating lists are constantly evolving for various reasons including splits and mergers of properties and/or businesses, demolition, and redevelopment of properties. New references will not match until the ratepayer advises of the change through the VOA.

4.2.17. Even where properties do not change hands, changes to company structures and other corporate changes occur on a regular basis. The design of the DBR system needs to be sufficiently flexible to enable these frequent changes to be assimilated into the system with the minimum of reporting requirements for businesses.

4.3. Receiving relevant business rates ‘data in’ to HMRC

4.3.1. Chapter 4 of the consultation document set out 3 potential options to gather the information needed from ratepayers (or their representatives) to enable accurate matching of business rates and tax information. This section provides a summary of the feedback received for the different options. The 3 options referred to here are:

• option A – collecting a tax reference through the new VOA duty
• option B – collecting a tax reference through BAs
• option C – collecting property references through an HMRC system

‘Data in’ from ratepayers

Question 8: In which type of customer journey would it be easiest to provide your reference number(s) (option A, B or C) and why? Would any of the options be particularly difficult?

How people responded

4.3.2. The response rate to this question was 76%, of which 72% favoured option A as the easiest way to provide reference numbers, 17% chose option B and 11% option C. Most of those who favoured option A were stakeholders representing businesses, agents, and billing authorities.

Option A (VOA) – this option suggested collecting a tax reference number as part of the new VOA duty processes.

4.3.3. Respondents who preferred option A supported their choice by stating the simplicity in the customer journey as it would build on and tie in with the new VOA duty. This would appear to the ratepayer as one process, in providing the necessary information, and through one avenue, therefore reducing the administrative burden. Respondents also confirmed that the easiest reference number to provide would be the tax number as it was one that they would most likely have at hand or find easier to access.

4.3.4. There was also support for the VOA and HMRC aspiration to use the same log-in service as this may make it possible to infer a match behind the scenes (this would be subject to it being technically possible to achieve). Some respondents suggested that where a reference number could be matched behind the scenes it would be essential to have the reference number confirmed by the ratepayer to verify the match.

4.3.5. Most ratepayers with large property portfolios across several BAs supported option A as it would be the least burdensome process for them, as in option B they would be required to engage with several BAs, and in option C they would potentially be supplying the same information twice: to both the VOA and DBR.

4.3.6. There was some concern about option A being a change to the normal process for ratepayers, as they are used to engaging with the BAs for most business rates related issues (although, this will change with the new VOA duty). It was suggested that there should be robust user testing of any new system before rolling out to avoid disruption in the process.

Option B (BA) – this option suggested collecting a tax reference number through the BAs:

4.3.7. Most respondents did not favour this option as they felt option A would provide a more seamless customer journey in comparison. This option requires potentially interacting with multiple BAs, particularly for businesses with multiple properties over several BA areas.

4.3.8. The majority (70%) of the BAs that commented on option B highlighted the significant burden this option would place upon BAs’ workloads. It was also stated that different BAs have differing capacities and capabilities, so it would be extremely difficult to maintain quality and consistency across all 309 BAs.

4.3.9. Respondents who selected option B as the preferred journey to provide the reference number suggested that it would be the simplest process based on the fact that ratepayers already engage with the BAs regarding their business rates.

4.3.10. Some respondents suggested incorporating the collection of a tax reference into an existing process where the ratepayer engages with the BAs, like when accessing bills.

Option C (HMRC) – this option suggested collecting property references through HMRC:

4.3.11. Many respondents opposed option C as it would be potentially repeating a similar process as to the new VOA duty, and they felt it was unnecessary to create a new process to gather the same or similar information. It was noted that it would be particularly burdensome for businesses with multiple properties.

4.3.12. Respondents also stated this option would add further complications as property reference numbers are not as easy to access, as they are not used as much as tax references.

4.3.13. Some suggested that if this option were chosen then it would be better to use an existing HMRC process to collect the property details to reduce the admin burden on ratepayers. Whilst others stated it would not be as straightforward as some ratepayers are liable for multiple/different taxes and there was no easy singular process to insert the property reference collection into.

Question 9: What are the main challenges presented with each ‘data in’ option and how could they be addressed?

Some respondents shared their general views on all 3 of the ‘data in’ options:

4.3.14. A few respondents raised the issue of ratepayer engagement, and how that would be impacted based on how complex or simple the process is and the administrative burden that it places on businesses. A complicated process with significant work involved will deter engagement, especially if businesses see little benefit from the new system.

4.3.15. Some respondents were concerned about the current lack of statutory obligation on the ratepayer to notify BAs or the VOA of their liabilities (this will change with the new VOA duty). This would impact the effectiveness of the DBR platform, as without obligating the ratepayer to engage with the DBR process, the system will be restricted to the data that has already been collected.

4.3.16. A few respondents were concerned that the addition of HMRC into the business rates domain makes it more complicated for ratepayers to understand their responsibilities to different parts of government, so sufficient guidance, including on how to access support, will be important.

Some specific comments concerning the different options:

Option A

4.3.17. A representative body raised the issue of option A being dependent on the new VOA system, which is still in development stage and therefore the DBR design work is based on assumptions, which poses a risk.

4.3.18. The view was also expressed that for businesses with large portfolios, if the new system requires inputting a tax reference number for each property, this will be a huge administrative burden. A suggested solution was to have in place a process to be able to provide the reference number in bulk for all properties.

Option B

4.3.19. Most respondents that opposed option B stated it was due to the significant burden that this option will place upon larger businesses with liabilities spanning multiple BAs. This would potentially entail providing all the different BAs with the reference number.

4.3.20. Around 38% of the respondents that answered this question stressed the additional burden this option will place upon BAs. They would need to update and upgrade IT systems, or maybe even acquire a completely new IT system. Some respondents highlighted the cost implications of option B, stating it would be the most expensive and complex system to deliver due to the number of BAs involved.

Option C

4.3.21. Nearly half of the respondents who commented on this question stated this option will place a significant burden on ratepayers, especially larger businesses with multiple properties. They suggested opportunities should be explored to use processes that ratepayers will already be using, rather than introducing new ones.

4.3.22. A couple of respondents highlighted that this option would entail engaging with all taxpayers (around 5 million) regardless of whether they are a ratepayer or not, and therefore place unnecessary burden on taxpayers who are not liable for business rates (and therefore not within the scope of DBR).

Question 10: Under option B – what process would be best for ratepayers (or their agent) to provide their tax references to a BA and why? Or would a standalone process be preferable?

How people responded

4.3.23. Around 58% of respondents answered this question, of which:

• 39% of respondents did not state a preference regarding the best process for ratepayers to provide the reference number
• 30% thought it would be easier for ratepayers to provide the tax reference number through a standalone system
• 20% suggested using an existing process, but no appropriate suggestions were provided, and
• 11% suggested using the BA registration process to capture the reference numbers from new ratepayers but acknowledged this would not help with existing ratepayers

Question 11: Under option C – what process would be best for ratepayers (or their agent) to provide their property references to HMRC and why? Or would a standalone process be preferable?

How people responded

4.3.24. Of those who responded to this question:

• 60% were either restating that they are against this option, or the comments were not relevant to the question
• 23% expressed the better option to collect the tax reference number would be through an existing HMRC process, (but no suitable suggestions were presented)
• 17% suggested a standalone process

4.3.25. There was a suggestion by a respondent to integrate the DBR system with the VOA’s CCA platform to make it easier for the ratepayers to provide/confirm their property references. This would help avoid duplication of admin burden on ratepayers.

Question 12: To what extent would ratepayers expect to log in themselves to provide tax or business rates information with a single set of verified credentials (rather than setting up multiple credentials or using an agent)?

How people responded

4.3.26. Approximately 55% of respondents engaged with this question, of these:

• 41% stated they would log in themselves and use the same credentials
• 9% stated they would log in themselves but use different credentials
• 32% stated they would ask an agent to provide the information
• 18% stated they were responding on behalf of multiple ratepayers

4.3.27. The majority of comments by respondents to this question supported the need for a simple log in process. This would ensure higher compliance by making it as easy as possible to comply.

Question 13: Other than those outlined in this document, are there any options for how DBR might collect data to enable matching of taxpayer and ratepayer information, that would work better to achieve the policy aims?

How people responded

4.3.28. Most respondents had no other suggestions on how best to collect data to enable matching.

4.3.29. To help with matching, one respondent suggested using new and other existing registers which collect property ownership data. They acknowledged that these registers will not necessarily provide or match details of occupation at any particular time but where possible, for DBR purposes, the government should explore and utilise information that has already been provided through existing processes to minimise the administrative burden for businesses.

‘Data in’ from BAs

Question 14: What processes might ratepayers (or their agents) have to put in place to meet their obligations under each option and what costs might this bring?

How people responded

4.3.30. A third of the respondents engaged with this question, sharing the following:

• a few respondents stated that for all of the options, businesses will most likely contract agents to help with the process and for larger businesses, there may be a need to have both rating and tax agents, as different data and processes are managed by each of them

• some stated the importance in keeping the process simple, so businesses are not forced to contract external help which will incur more costs

• some larger businesses already have Application Programming Interfaces (APIs) setup for communication with VOA and BAs, so there will be a need to either design a new process or make changes to existing APIs to supply the new information

4.3.31. For option A, some respondents stated that submitting the tax reference number as part of the new VOA duty will not require much effort and the costs would be marginal. Others pointed out that agents will have to amend their existing IT platform to incorporate capturing the relevant tax references for their clients, which they thought should incur minimal costs.

4.3.32. For option B, some respondents felt supplying tax references to BAs will entail a new process to be designed, as the current processes do not provide the opportunity to collect a tax reference. For businesses spanning several BAs, it may entail agents having to establish means of gathering, holding, and transferring information to individual BAs.

4.3.33. For option C, concerns were raised by agents regarding the ability to gather property information. They were concerned that potential non-compliance by ratepayers or inability to source the information could lead to delays. There were also concerns for larger businesses that this option could require their agents to submit multiple returns, leading to a significant increase in administrative costs.

Question 15: How much might you expect it to cost BAs to upgrade systems to export billing information to HMRC. Please provide the evidence or assumptions that support your estimate (this will help inform new burdens funding estimates)?

How people responded

4.3.34. Most respondents to this question were unsure of potential costings but welcomed the government’s early considerations, with some BAs and relevant software providers were willing to help arrive at some estimates once high-level designs were clearer to support a New Burdens assessment.

4.4. ‘Data out’ from HMRC: using DBR data

4.4.1. Chapter 5 of the consultation discussed the exchange of business rates data needed between central government and BAs, and how the linking of business rates and tax data could be used to support ratepayers and BAs. It sought views on the value of a service to allow ratepayers to view business rates data for all their properties in England alongside other tax information and how that might be achieved.

Question 16: Would you use a service that allows you to view business rates information for all your properties across England in one place, alongside other HMRC tax liabilities? Yes/No

If yes, how often and for what purposes?

If yes, how useful would you find such a service – on a scale of 1 to 10, where 10 is extremely useful?

If no, would being able to pay your bill(s) through the service change your response?

How people responded

4.4.2. Out of the 56% respondents who addressed this question, 57% answered that if the system was created, they would use a service that allows them to view, in one place, business rates information for all their properties across England alongside other HMRC tax liabilities.

4.4.3. However, it was apparent through user research carried out alongside the consultation and roundtables (which allowed for a more detailed/interactive discussion) that it was more of a ‘nice to have’ rather than something that would be of particular value. This was especially applicable to businesses with smaller property portfolios, as they see business rates as another ‘utility bill’ that is paid mostly by direct debit and filed for accounting.

4.4.4. Others commented that there was no business need for having tax information displayed alongside business rates information. What would be more useful based on user research, was for businesses with larger property portfolios to have business rates information for all properties in one place. However, it was also pointed out by agents and representative bodies that most businesses with large property portfolios already have systems, or outsource the service, to bring together the billing information for all their properties in one place.

4.4.5. Feedback from some respondents suggested the following benefits of being able to view their business rates billing information in one place:

• for businesses with property portfolios across multiple BAs they will be able to see all their information in one place
• for some businesses it may result in reducing costs as they may not need external expertise to provide this consolidated view
• would help with budgeting and forecasting

4.4.6. Of the 43% who responded ‘no’ to this question, most respondents commented that being able to also pay bills through this service would change their response, with one respondent stating that incorporating payment of rates bills should be an integral part of DBR. However, it was noted that being able to make payment through a DBR service could bring another level of complexity, given that BAs would remain responsible for collecting business rates.

4.4.7. One respondent also highlighted that detail of their business rates liabilities is already captured in their finance systems; therefore, this could be duplication of what is already available, and a separate system could confuse issues. A further issue highlighted is that BAs have different instalment due dates, it may not be possible to view real time liability owed unless billing is standardised across BAs.

Question 17: When thinking about how often (your) bills change, how often should the business rates billing information be updated? (for example, weekly, daily, or through real time look-up whenever a ratepayer seeks to view their billing information through the DBR service). Options: real time look up/daily/weekly/monthly/quarterly/annually

How people responded

4.4.8. Most respondents considered that business rates billing information should be updated in real time as any alternative would give rise to anomalies between the DBR system and bills provided by a BA, although respondents acknowledged that this would be dependent on the work involved and whether the updates would require manual or automatic input.

4.4.9. A reoccurring consideration by respondents was the size of the property portfolio. Larger portfolios tend to undergo changes all the time such as lease details, payment changes etc, whereas for smaller portfolios changes may be less frequent.

Question 18: Could DBR data help with targeting and administrating of reliefs? If so, for which reliefs would it be of most help and why?

How people responded

4.4.10. Respondents welcomed the government’s ambition to use DBR to target business rates reliefs better, particularly to support businesses in response to economic crises. Most of those who responded to this question suggested that DBR data would help both with better targeting of business rate reliefs and with BAs administering them. Small business rates relief (SBRR) was the main relief respondents felt DBR would help with, however other reliefs highlighted were retail, hospitality and leisure relief, charitable relief, hardship relief, and empty property relief.

4.4.11. Respondents felt DBR could help:

• support BAs with accurate application of reliefs, and if focused on streamlining and smoothing relief processes it would reduce administrative burden related to updating billing and hereditament information
• facilitate checks on eligibility for future relief schemes where subsidy controls are a factor
• mitigate rates avoidance and fraud, particularly in relation to SBRR
• assist in applying SBRR and any relief that applies a national cap, for example Retail, Hospitality and Leisure (RHL) relief

4.4.12. A concern was raised by respondents that business tax data may not always be the most up to date figures, so will not accurately reflect a business’ performance (for example, corporation tax data is based on previous years) so it may not be the most effective and accurate way to target reliefs if a business needed support urgently based on current circumstances.

Question 19: Is there any other data that DBR could provide to help billing authorities feel more confident when awarding reliefs and/or grants?

How people responded

4.4.13. Respondents suggested that the following would be helpful information for BAs:

• access to real income/profit figures and the nature of the business would help with reliefs, both eligibility and capping

• information on administration and strike offs would help compliance

• summary of the total of reliefs/grants received in a financial year, liabilities and reliefs claimed across a ratepayer/business portfolio

• centralised data would help tackle fraudulent ratepayer activity or evidence hardship

• a way of checking on subsidy controls (state aid), although one respondent did recognise this would place additional burden on BAs and would need to be funded accordingly

4.4.14. Generally, it was felt that having access to other BAs’ data through DBR would help minimise abuse of reliefs.

4.5. Compliance Regime

4.5.1. Chapter 6 in the consultation set out the government’s thinking on guiding principles for an accompanying compliance regime and explored a number of options to underpin the 3 data-in options.

Question 20: If option A for ‘data in’ is pursued, do respondents think DBR should be included within the sanctions regime for the new VOA duty or have a separate sanctions regime?

How people responded

4.5.2. The response rate for this question was 71%, of which 75% agreed that if option A is pursued, they would prefer DBR to be included within the sanctions regime for the VOA’s new duty.

4.5.3. Those in favour of a single penalty system felt that it would ensure that the burden on the ratepayer is minimised, highlighting that most ratepayers will regard DBR’s additional information request to be as part of the same process and part of the overall package of information required by government.

4.5.4. In order to allow enough time for smaller businesses to adapt to the system and their new obligations, a few respondents asked the government to consider taking a light touch approach to compliance during the first 12 to 36 months of implementing DBR.

4.5.5. A few respondents said there should be no sanctions regime all together. Some of the reasons given were:

• where tax references are identified ‘behind the scenes’, ratepayers should not be sanctioned, instead there could be an optional requirement for ratepayers to confirm that the tax references are correct, this could then be accompanied by a widespread education programme

• the government could consider highlighting the benefits of DBR and encouraging engagement with it through communication and demonstration of the proposed benefits, rather than through sanctions – such that ratepayers comply because of not wanting to miss out on the benefits

• failure to provide the additional information would not have a negative economic impact to the government and as such there should not be an accompanying sanction regime

4.5.6. Generally, it was felt that a single sanction regime where DBR is aligned with VOA’s regime would be the better choice for the customer, though it was highlighted that further consideration would be needed for those who are digitally excluded.

Question 21: If separate, or if options B and C are pursued, do ratepayers have views about adopting a similar penalty regime to the one proposed for the VOA’s new duty?

How people responded

4.5.7. Only 35% of the respondents answered this question, of which just under half were in favour of adopting a similar penalty regime to that proposed by for the VOA duty, and the remainder were split between being against or neutral.

4.5.8. Stakeholders who favoured adopting a similar penalty regime to the one proposed for the new VOA duty, stated that not doing so would be burdensome and confusing for the ratepayers.

4.5.9. Some of the following reasons were provided as to why a sanctions regime should not be in place:

• some disagreed with a sanction’s regime in principle, with one respondent suggesting that if a regime was to be introduced, the government should consider a fixed sum penalty which would be administered after warnings and reminders

• another respondent suggested that DBR may take inspiration from BAs by withdrawing ratepayers ‘rights’, for example, BAs may withdraw a ratepayer’s right to pay by instalment if payment is made late – in the case of DBR, where a ratepayer fails to provide the required information, they could lose access to being able to use the CCA service

• DBR proposals seemed to largely benefit the government, so they felt the application of penalties appeared to be disproportionate, it was suggested that the government may wish to consider a small discount given on the rates bill when the data is provided

Question 22: What concerns do you have about a DBR sanctions regime?

How people responded

4.5.10. When answering this question stakeholders highlighted that when designing an effective regime, the government would need to consider that:

• penalties need to be transparent, with adequate timelines, and proportionate to the size of company and risk to the Exchequer

• even though a sanctions regime would help produce a more reliable data base and ensure compliance from ratepayers, engagement following sanctions would still need to be in place to try to avoid any further penalties being issued

• it is important to ensure enough time is given to ratepayers who will also have to engage with VOA duty

• though sanctions are necessary to manage a successful rating system, the government would have to consider the appeals infrastructure for DBR and ensure ratepayers are aware of it

• support for small and medium size enterprises is needed to ensure compliance

• sanctions should be introduced gradually and not immediately activated

Question 23: Do you envisage risks with applying the principle of conditionality to new or redesigned reliefs? If so, how can these be mitigated?

How people responded

4.5.11. Of the 37 respondents who answered this question, 73% responded that they envisage some risks with the application of the principle of conditionality:

• the financial assistance removed from businesses may risk hardship for businesses currently struggling and may not be proportionate to the failure to comply

• exceptions need to be considered when applying the principle of conditionality, for example, businesses or organisations who may need a business rates relief urgently but are either not yet registered or unable to locate their tax information in sufficient time to obtain such relief, like in the case of change in control or the death of an owner-manager

• concerns around the fact that HMRC might make the decision to withdraw the relief on the basis of non-compliance, but the BA would be dealing with the direct consequence of this decision, making the customer journey more complicated for the ratepayer

4.5.12. Those who answered that they had no concerns and envisaged no risks with applying the principle of conditionality highlighted that conditionality is already used by the government in many other areas (such as in proving eligibility for housing benefit, council tax reduction scheme, universal credit, council tax exemptions and discounts) which require individuals to provide information in order to secure financial benefit. Respondents stated that more recently, such an approach was used with the various COVID-19 grants and as such could continue to be used for DBR. It was also highlighted that conditionality is widely used within the business rates system already, as many BAs will not give a relief without having been provided certain information.

Question 24: Are there alternatives to penalties not explored in this document that the government should consider?

How people responded

4.5.13. This question was answered by 24 respondents of which 67% answered ‘yes’. However, of these, only 38% suggested alternatives, with the remainder stating that a sanctions regime should not be considered for DBR’s purposes.

4.5.14. Some of the alternatives suggested were:

• only granting premises licences, food hygiene certificates and/or the ability to engage with CCA where ratepayers have met their DBR obligation

• alignment with Companies House penalties and sanctions regime for the most uncooperative cases

• giving ratepayers the option to opt out of DBR

4.6. Other considerations

4.6.1. Chapter 7 in the consultation document explored respondents’ views on agents being authorised by the ratepayer to view business rates information through the new DBR services and provide the data matching information needed for DBR on their behalf. Respondents’ feedback would help the government to understand agents’ needs and support in developing and designing a seamless DBR process for them.

Question 25: What are ratepayers’ and agents’ views on whether ratepayers will want their agents to discharge their duty to provide the mandatory reference numbers needed for DBR?

How people responded

4.6.2. The response rate for this question was 42% of which 75% (mostly representative bodies and agents) stated that they would like agents to be able to use the system on behalf of businesses to provide the mandatory information required for DBR.

4.6.3. A few respondents highlighted the importance of ensuring the ratepayer is able to provide the necessary authority to agents, such that the information the agent can access is ‘ringfenced’ to business rates information only or for a tiered login system where the ratepayer can select the information that can be accessed by agents.

4.6.4. Respondents also highlighted concerns regarding the additional costs that businesses may need to incur as a result of DBR, if they need to contract agents to help them comply.

Question 26: Where a ratepayer wants an agent to discharge their duty to provide the mandatory reference numbers needed for DBR, do agents know/can they easily obtain the tax and property references set out in Chapter 3? Are any more or less easily accessible?

How people responded

4.6.5. This question was answered by 42% of the respondents of which 50% stated there would be no difficulty in agents obtaining the necessary references, 19% of respondents were neutral with 31% expressing some concerns.

4.6.6. Some respondents noted that property references are readily available from the VOA website, and BA account references can be obtained from the latest business rates bill.

4.6.7. Responses however highlighted some concerns that:

• rating agents do not currently have access to HMRC tax references (although may have a company reference number and are likely to know the VAT number of their clients), so they would have to be specifically provided to them by the taxpayer (or will need to authorise the tax agent), and so would add a layer of complexity for larger entities who use tax agents.

• difficulty may arise if a business has different agents for tax and business rates – the tax agent holding the required information is different to the rating agent that will be providing the reference number for DBR

Question 27: What are agents’ views on the benefits and any drawbacks of agents being able to access the ratepayer’s business rates billing information through DBR?

How people responded

4.6.8. Respondents shared some benefits of having access to DBR system:

• it would enhance agents’ ability to ensure the right non-domestic rates are being paid and the correct reliefs are being applied

• having real time access to all business rates billing information in one place would enable agents to view the real time status of accounts and help with dealing with matters such as incorrect recovery action

4.6.9. Respondents shared some potential drawbacks:

• if the business has different agents for tax and billing rates purposes, there would be little benefit to either agent having access to the information they do not need to deal with

• a business might have concerns about an agent appointed for a limited purpose having access to other information

• there are unlikely to be any significant benefits of an agent being able to access the ratepayer’s business rates billing information through the DBR system unless the new system would avoid the need for the current ‘Claim’ process involved in CCA

Question 28: Do tax agents foresee any change in their clients’ expectation of them as a result of being able to access their business rates billing information alongside their other tax information? If so, how and what are their views on the benefits and disbenefits of that change?

How people responded

4.6.10. Most respondents did not answer this question. Of those who responded:

• more than half felt that it is not expected that the DBR proposals in their current form would change ratepayers’ expectations of their agent

• some respondents expressed that the taxpayer may not want to share their tax information with rating agents, as they don’t usually have access to such information

5. Next steps

5.1. We are grateful to have received such comprehensive and thoughtful responses to the consultation. We have read each response carefully and have attempted to reflect the commonly expressed views in this summary of responses.

5.2. The introduction of the DBR obligations will require legislative change. The government will seek to identify a suitable legislative vehicle to take these changes through Parliament.

5.3. Work is ongoing on the detailed design of DBR and will continue to take account of responses to the consultation, as well as user research and ongoing stakeholder engagement. HMRC and the VOA will work together on the design of a single business rates service on gov.uk that will allow ratepayers to provide the data needed for DBR, alongside the information required by the new VOA duty as part of an integrated customer journey.

5.4. The government will continue to engage with Billing Authorities and their software providers to develop a more detailed understanding of the New Burdens costings, as the design of DBR develops.

5.5. The government will continue to engage with the main representative bodies who responded to the consultation, and with other stakeholders as appropriate, including through working group formats, as the design of DBR progresses.

6. Annex

List of stakeholders consulted

The government is grateful for the contributions of all those who responded to the consultation. Below is the list of representative bodies and rating agency firms that engaged in the consultation:

• Altus
• Association of Account Technicians
• Association of Chartered Certified Accountants
• Association of Convenience Stores (ACS)  
• Association of Tax Technicians
• British Chamber of Commerce (BCC)
• British Independent Retailers Association (BIRA)
• British Property Federation (BPF)​
• British Retail Consortium (BRC)
• CAPITA​
• Chartered Accountants Ireland
• Chartered Institute of Public Finance and Accountancy (CIPFA)​
• Chartered Institute of Taxation (CIOT)
• CIVICA
• Colliers
• Confederation of British Industry (CBI)
• Federation of Small Business (FSB)
• Institute of Accountants for Scotland
• Institute of Chartered Accountants in England and Wales (ICAEW)
• Institute of Directors (IOD)
• Institute of Revenues Rating and Valuation (IRRV)
• Local Government Association (LGA)
• NEC Software Solutions ​
• Rating Surveyors Association (RSA)
• Royal Institute of Chartered Surveyors (RICS)​
• VOA’s Business Rates Advisory Forum (BRAF)

1. Any data collected through DBR will be stored and shared by HMRC in line with its existing guidance and procedures for the protection of personal data, as well as with any existing Memorandums of Understanding (MOUs) (or, where relevant, new MOUs). ↩