The Court considered the rateability of a residential caravan site. The caravans were on wheels and retained their mobility although they were jacked up to keep them stable.
Held: Although a chattel is not a rateable hereditament by itself, it may become rateable together with land, if it is placed on a piece of land and enjoyed with it in such circumstances and with such a degree of permanence that the chattel with the land can together be regarded as one unit of occupation.
Lord Denning MR said: ‘the correct position today is that, although a chattel is not a rateable hereditament by itself, nevertheless it may become rateable together with land, if it is placed on a piece of land and enjoyed with it in such circumstances and with such a degree of permanence that the chattel with the land can together be regarded as one unit of occupation.’
Judges:
Denning MR, Dankworths, Salmon LJJ
Citations:
[1966] 2 QB 484
Jurisdiction:
England and Wales
Citing:
Cited – London County Council v Wilkins (Valuation Officer) HL 1957
Four builders’ moveable huts, which had been erected as temporary structures on a site for 18 months, only one of which was moved from one part of the site to the other during that period, were claimed chattels and therefore not rateable.
Cited by:
Cited – Cinderella Rockerfellas Ltd v Rudd (Valuation Officer) CA 11-Apr-2003
The taxpayer appealed against a rating assessment on a barge permanently moored at a riverbank. He claimed that as a chattel, it should not be rated.
Held: The vessel was a chattel, but its occupation could be an occupation of the riverbed. . .
Cited – Reeves (Listing Officer) v Northrop Admn 6-Mar-2012
The respondent occupied a tugboat with his family as his home. The appellant authority had sought to charge council tax, saying that it was a dwelling. The boat was not a houseboat but a live-aboard seagoing vessel, registered in the Small Ships . .
Lists of cited by and citing cases may be incomplete.
Rating
Updated: 31 July 2022; Ref: scu.181039