We recognise the desire to collect Council Tax where possible and so a review of the current exemptions is sensible. However, we are concerned that there has not been a detailed analysis of the impact of the proposal to collect Council Tax on repossessed homes and we do not agree with the rationale to remove the Class L exemption.

As the property remains empty whilst in possession, we do not see why Council tax would be payable, as the lender themselves would make very limited use of the provisions and services funded by Council Tax.

It is not known from the proposals as to how the local authority will be made aware that the lender is now liable for council tax and at which point the lender becomes liable. It is not known whether the lender themselves will be required to notify the local authority or vice versa. It is also not known how this notification process will work.

The Government will need to consider carefully how the billing arrangements should be managed and a detailed cost benefit analysis must be undertaken prior to pressing ahead with this proposal. The BSA is very concerned that this alone could result in significant costs to local authorities as well as to lenders.

Should Government wish to press ahead with the proposals, despite our objections, it is imperative that a full and detailed impact assessment is conducted on these proposals prior to pressing ahead with change. The assessment needs to consider:

- How lenders make use of the services provided by Council Tax and whether this use is proportionate to the Council Tax that lenders would be required to pay.
- How the billing arrangements will be managed from both the lender and local authority perspective.
- A detailed cost benefit analysis

We welcome the common sense approach taken on council tax for properties with photovoltaic panels installed as part of a rent a roof agreement. We agree that domestic scale photovoltaic panels should be treated as a part of the domestic property, rather than being individually assessed for business rates.

The full response can be accessed via the link below:

Technical Reforms of Council Tax - BSA Response