Our Work

BPF Response to the Future Buildings Standard consultation

what: We have submitted a response to the government’s latest consultation on updates to Parts L and F of the Building Regulations, including tightened energy efficiency and ventilation standards for non-domestic buildings.

our view: Whilst the government’s intent to tighten standards is correct, we believe the level of ambition, timescales, and preferred methodology must be revisited.
Our Work

Review of the UK Funds Regime

What: We have submitted our response to the government’s review of the UK funds regime – part of the government’s ambition to bolster the UK as a destination for the investment management industry.

Our view: We support the government’s bold ambitions. Our main recommendations include: the creation of a new government task force bringing together expertise from tax/regulation/corporate law, to recognise the multifaceted and long term nature of the challenge; a broadening of the REIT rules to better enable REITs to channel investment to support our net zero goals and other government priorities; and the creation of new fund vehicles which are suitable for institutional investors and joint ventures.

Our Work

BPF Response – Performance-based ratings in commercial buildings

what: We have submitted our response to the BEIS consultation on introducing a new policy framework for performance-based energy ratings in commercial and industrial buildings over 1,000m2

our view: We were directly involved in developing this policy framework and are therefore highly supportive of the proposals. We have provided a few comments on areas for future improvement.
Our Work

BPF response to the Call for Evidence on Local Authority Remote Meetings

What: The government is consulting on the effectiveness of remote local authority meetings including virtual planning committee meetings which had been in operation since the start of the pandemic until early May of this year.

Our view: We are supportive of the move towards holding more planning committee meetings remotely albeit there will be scenarios where a physical meeting is more appropriate. Local authorities should be empowered to judge the best meeting method in light of the matters to be discussed with input from all interested parties. National guidance should also be produced to assist local authorities in determining the best format.
Our Work

BPF response to FCA consultation on the LTAF (Long Term Asset Fund)

What: As part of the Government’s wider ambitions to bolster the UK as a centre for asset management, the FCA have consulted on a new regime to enable UK-authorised open-ended funds to invest more efficiently in long-term, illiquid assets.

Our view: Given the illiquid nature of real estate investment, we particularly welcome moves to create a new fund to facilitate investment in long-term, illiquid assets and, as such, we support the introduction of the LTAF. This has the potential not only to increase investment but also to help address some of the major challenges that the UK faces – including our net zero carbon targets, the regeneration of our high streets, and the development of more high-quality homes.
Our Work

Residential Property Developer Tax (RPDT)

What: As part of the government’s commitment to help fund cladding remediation works, they have proposed a new tax on residential property developers.

Our view: This new tax is disproportionately complex, in the context of the level of revenues it will raise. It will be particularly penal on investment asset classes, like BTR and PBSA, which will impact on development viability of new rental homes – we therefore call for a carve out for investment asset classes.

Our Work

BPF response to land exemption CFE

We responded to the Government’s call for evidence on simplifying the VAT land exemption. While we welcome HMRC’s interest in this area, we do not feel that the “ideas for simplification” set out in the consultation would make life easier for taxpayers; they would most likely make things more difficult. Instead, we urge HMRC to focus on providing more certainty through better guidance, improving taxpayers’ experience of the VAT system through better use of technology and reforming selected areas of the legislation.

Our Work

The Shopkeepers’ campaign’s response to HM Treasury’s business rates review consultation - more frequent revaluations

The Shopkeepers' Campaign continues to call for fundamental reform of business rates for retail with annual revaluations rather than settling for the 3 yearly valuation cycle the Government’s latest consultation is proposing. Read why here
Our Work

BPF response to more frequent business rate revaluations

What: As part of the Government’s Fundamental Review of Business Rates, Ministers are proposing to move to a 3-yearly cycle of revaluations in England.

Our view: Moving to a 3-yearly cycle is a step forward, but we want Government to go further. We are calling for Ministers to publish a roadmap for delivering annual revaluations and a one year AVD. We welcome proposals to increase transparency but this must include transparency over how individual valuations are determined. We oppose proposals to introduce fees and restrict appeals. In particular, we make clear that we can not accept any restrictions on the right of property owners to appeal in cases where they are not the ratepayer.
Our Work

BPF response to FCA consultation on climate-related disclosures

What: The Financial Conduct Authority (FCA) is consulting on enhancing climate-related disclosures by asset managers, life insurers and FCA-regulated pension providers.

Our view: Given the urgency and scale of the challenge we face in transitioning to a low-carbon economy, we welcome proposals to increase transparency which allow clients and consumers to make better informed choices, while remaining proportionate for firms. However, we call for further engagement with the FCA to ensure that rules and guidance work for the real estate sector.
Our Work

Building Safety Levy – BPF response

A DLUHC consultation on the new Building Safety Levy to be applied at Gateway 2 of the new building safety regime. We highlight the damage this policy will do to other Government objectives, for example its push to have more housing growth in 20 key cities. We also draw out a number of areas of the new levy that could draw on existing practices, particularly with the Community Infrastructure Levy.
Our Work

BPF Response to Government consultation on draft RPDT legislation

What: The BPF has responded to the Government’s technical consultation on the draft legislation for the Residential Property Developer Tax (RPDT). Final clauses will be included in the 2021/22 Finance Bill.

Our view: We welcome the decision to exclude PBSA and some BTR development, but call for further amendments to exclude all forms of BTR activity from the scope of the RPDT. We also call for all forms of affordable housing to be exempt from the new tax, and make a series of recommendations on how the RPDT regime can be simplified and how taxpayers can be supported as the new tax is introduced.