[2025] UKUT 00343 (LC)

Mr Chris Royle MRICS DipRating has worked for the Valuation Office Agency since 1985 and since 2001 has been responsible for providing guidance to valuation officers on compiling and maintaining list entries for advertising hereditaments. His role includes discussion of the VOA’s schemes of value with the advertising industry and its representatives.

In his expert report Mr Royle states that his evidence for this appeal is the same as that provided for Hitchings and Moore, where it was examined at an oral hearing. He had found no further or different evidence or analysis since that would cause him to change his approach to the valuation of the digital advertising hereditaments in this appeal.

It is therefore not necessary for me to reiterate Mr Royle’s evidence in detail, but rather to review the Tribunal’s analysis and conclusion in Hitchings and Moore, at [45 to 48]:

“45.

I have separated Mr Royle’s evidence into two limbs. The first is a batch of evidence which seems to suggest that at the valuation date, the industry was applying a ratio of 1:6 to digital signs compared with static – see the note of the meeting with CCUK, and the VORC return.

46.

We then have a number of commercial agreements, which in my judgment are less reliable - partly because they are national agreements covering many hundreds of locations, partly because they do not provide a reliable basis to provide evidence of arm’s length rents, but mainly because those upon which Mr Royle places weight were entered into many years after the Antecedent Valuation Date of 1 April 2015. But the supermarket agreements are helpful in suggesting that digital signs are of more value than scrollers.

47.

It is uncontroversial that a scroller display is of higher value than a static display, with a 3:1 ratio. I have no doubt that a digital display must have a higher value than a scroller, because it can show more advertisements in a more sophisticated way.

48.

I can understand why the VTE might be reluctant to increase the ratios applied to digital signs. But much of the material before me now was not available to the VTE. While I have no evidence of like-for-like rents, on balance there is sufficient evidence to warrant a ratio of 6:1 for the right to use digital signs. Whether that ratio increases in future valuation lists is an argument for another day.”

The Tribunal in Hitchings and Moore found sufficient evidence to warrant a ratio of 6:1 for the right to use digital signs at the AVD of 1 April 2015. I have received no new evidence to unsettle that finding, which I now endorse in this appeal.

The appeal in this case is allowed and the rateable values of the hereditaments at the AVD of 1 April 2015 shall be based on a multiplier of six to the relevant basic static display value, and the entries in the 2017 rating list shall be as set out in the Appendix to this decision.

Appendix – 21 Advertising Right Subject Hereditaments