Determining the rateable value of advertising on bus shelters

The valuation methodology for determining the rateable value of advertising rights must move with the times. The Upper Tribunal (Lands Chamber) has considered this issue in Valuation Officers v Valuation Tribunal for England [2025] UKUT 6 (LC). Under section 64 of the Local Government Finance Act 1988, a right is a hereditament if it is a right to use any land to exhibit advertisements, whether reserved to the owner of the land or let out to others. It is assumed that the reservation or grant includes a right to use any structure or sign – even if provided after the reservation or grant – for the purpose of exhibiting adverts by the occupier. The word “structure” includes a hoarding, frame, post or wall. The case concerned bus shelters in Manchester and Sheffield. The central Manchester shelter had a green roof, Wi-Fi hotspots and areas to sit and stand at raised tables. The advertising sign was a two-sided, back-to-back digital display, 1.8m tall and 1.2m wide, a size known in the industry as “6-sheets”. The Sheffield shelter, on the outskirts of the city, was more modest, with a digital internal display and a static display on its outer face. There are three main types of 6-sheet displays: static displays or backlit boxes which are changed manually; scrolling displays which have two or three adverts on a scroll; and digital displays of differing sophistication. The hereditaments in question were standard digital billboards. The Valuation Tribunal for England in each case reduced the rateable value for the shelters. Manchester was reduced from £7,200 to £3,600 (a 1:3 ratio) and Sheffield from £4,800 to £850, on the basis that digital displays were no more valuable than static displays. The valuation officers appealed. Having heard valuation evidence, the tribunal decided that at the valuation date the industry was applying a ratio of 1:6 to digital sites compared with static ones. Commercial agreements were less reliable, but agreements with the larger supermarkets also suggested that digital signs were more valuable than scrollers. The value of the sites for static display was agreed at £600 per side in Manchester and £425 in Sheffield. It was uncontroversial that a scroller display had a higher value than a static display with a 1:3 ratio. Consequently, it followed that a digital display must have a higher value than a scroller because it could show more adverts in a more sophisticated display. The tribunal considered that there was sufficient evidence to warrant a ratio of 1:6 for the right to use digital signs. This resulted in a figure for Manchester of £7,200 and £2,950 for Sheffield. Louise Clark is a property law consultant