The Government is consulting on changes to the Business Rates Empty Property Relief in order to reduce opportunities for avoidance. Based on new data on typical vacancy periods, we do not think the reforms suggested are appropriate, and we have suggested that the Government should instead increase the Empty Property Relief from 3-6 months to closer to 12 months, to better reflect typical vacancy periods in the market. We have also suggested reinstating the 50% discount after the initial EPR period will better support property owners with longer term vacant units and reduce incentives for empty rates mitigation activity.