Amanada Hitchings v Shoosmiths LLP & Anor
Decision date: 9 July 2025
Neutral citation: [2025] UKUT 224 (LC)
Overall AI summary confidence: medium
Short overview
This short overview is intended to summarise the case, issues and outcome so far as they are supported by the judgment.
AI confidence in this short overview: medium
This appeal concerned how to value Category B (tenant) fit-outs for rating purposes at two Grade A offices (Shoosmiths, Manchester; Mando, Liverpool) where direct Category B comparables are scarce. The Upper Tribunal accepted that, absent reliable comparables, the amortised cost to the tenant of the Category B fit-out or a landlord's capital contribution can be significant evidence of the annual value uplift above Category A. The Tribunal rejected the Valuation Tribunal's use of arbitrary fixed uplifts (£10/£15/m2) as a general approach and directed that each property be reassessed applying the accepted principle.
Ratio decidendi
This summary is intended to identify the ratio decidendi, meaning the legal reasons for deciding and the binding part of the decision.
AI confidence in this ratio decidendi summary: medium
Where reliable market comparables for Category B uplifts are not available, evidence of the amortised cost to the tenant of undertaking the Category B fit-out—or of a landlord's capital contribution towards such works—may constitute material evidence of the annual value uplift for rating purposes under the rating hypothesis that the property is valued in its physical state on the material day.
Obiter dicta
This summary is intended to identify obiter dicta, meaning observations made by the way that were not necessary to deciding the case and are not binding.
AI confidence in this obiter dicta summary: medium
The Tribunal observed (non-bindingly) that a contractors’ or cost-based valuation method is an established, more sophisticated alternative to simple amortisation where comparables are lacking, and noted market practice for Grade A offices tends to favour landlords providing only Category A to preserve the tenant pool, making speculative Category B uncommon.