Council tax liability appeals to the Valuation Tribunal
A local authority decision about council tax liability can be appealed to the Valuation Tribunal England.
Right of appeal to the VTE
The Local Government Finance Act 1992 provides council tax payers with the right to appeal to the Valuation Tribunal England (VTE).
The VTE is an independent tribunal. It deals with complaints about council tax liability and chargeable dwellings, as well as other issues such as banding, exemptions, and penalty charges.[1]
Who has the right to appeal
A person can appeal to the VTE if they are aggrieved with a relevant decision of the local authority. The aggrieved person could be someone other than the assumed liable taxpayer.
Decisions that can be appealed
A person can appeal to the VTE if they are unhappy with a decision that a dwelling is a chargeable dwelling, or that they are liable to pay council tax on a dwelling.[2]
The VTE can deal with appeals about a calculation made by a local authority about the amount they are liable to pay.[3] This includes decisions about the taxpayer's entitlement to a discount, reduction or exemption.[4] It also includes decisions about estimated amounts.[5]
The VTE is the only body with jurisdiction to decide the issue of liability for council tax. The fact a magistrates' court has made a liability order does not affect its ability to consider a liability appeal.[6]
Read more about the magistrates court liability order process in Council tax billing and recovery on Shelter Legal.
Decisions that cannot be appealed
The VTE has no jurisdiction to hear appeals about billing and enforcement.
The Local Government and Social Care Ombudsman can deal with complaints about local authority enforcement. The Enforcement Conduct Board deals with complaints about enforcement agents.
Read more in A practical guide to council tax complaints in Shelter tools and guides.
Notifying the local authority
The appellant must serve written notice of their complaint on the billing authority before an appeal can be raised in the VTE.[7]
The VTE normally strikes out appeals where a complaint notice has not first been served on the local authority.[8]
The appellant's original complaint to the local authority counts as notice of the appeal. There is no requirement to serve an additional notice as long as the complaint contained all the relevant information.[9]
What must be included in the notice
The notice must state the ground for appeal and the reason for the appeal.[10]
The notice must include the:
full name and address of the appellant
address of the relevant dwelling
date on which the written notice was served, and to which local authority
date on which the appellant was notified the local authority has not upheld the complaint
ground for the appeal
reason for the appeal
The complainant receiving a council tax bill they are not liable to pay is a ground for appeal. The reason for the appeal is why they are not liable to pay, for example, because the dwelling is not their sole or main residence.
The notice must state if the appeal raises the same issues as an ongoing appeal about Housing Benefit or Council Tax Support.
Local authority response to the complaint
The appellant can proceed with a VTE appeal where the local authority has failed to resolve their complaint, or if it fails to respond.
The local authority has two months from the complaint to either reject it, or take steps to remedy it.
Local authority rejects the complaint
The appellant can appeal if they are notified in writing that the local authority does not agree it is at fault.[11]
Local authority does not resolve the complaint
The appellant can appeal if they are notified in writing that the local authority has taken steps to resolve the complaint but they are not satisfied with the response.[12]
Local authority does not respond
The appellant can appeal if the local authority does not respond within two months of the complaint.
A response from the local authority that does not expressly state it is a statutory notification of its rejection or resolution of the complaint is not counted as a response.
Time limits to appeal to the VTE
When the billing authority has responded to the complaint with a decision, the complainant has two months to start their appeal to the tribunal.
The decision could have rejected the complaint outright, or accepted the complaint but not to the satisfaction of the complainant.
No response from billing authority
The complainant has four months from the date of their initial complaint if they receive no response at all. The four months is made up of the two months the local authority has to respond, and the two months for the appellant to lodge their appeal.
Out of time appeals
The VTE can allow a late appeal where it is satisfied that the appellant's failure to appeal within the time limit is for a reason outside their control.[13]
How the appellant starts the appeal
The appellant can start an appeal by completing the correct form on the VTE website.
There is a different form for each of the areas for appeal:
banding
liability
reduction
completion notice
invalidity notice
penalty notice
Each form asks for details of the billing authority, along with the decision date, and the reasons for the appeal.
There is a function to upload copies of correspondence received from the billing authority.
Find the council tax appeal forms on the VTE website.
Tribunal hearings
Unless a decision is made on the paperwork alone, a hearing is held online.
The VTE can arrange an in person hearing if the tribunal President is satisfied that the appellant cannot engage with a remote hearing.
Conduct of the appeal
The Valuation Tribunal has published a Consolidated Practice Statement containing its process for dealing with council tax appeals.
Read the Consolidated Practice Statement on the VTE website.
How the VTE deals with the appeal
The VTE issues directions to the appellant and the billing authority. It can strike out appeals it does not have the jurisdiction to deal with.
Directions to parties
Directions are instructions issued by courts and tribunals to parties in a case. They normally cover submission of documents and evidence, along with deadlines that must be complied with.
There are standard directions for VTE appeals contained in the Consolidated Practice Statement.[14]
If the parties do not comply with directions the VTE can:[15]
strike out or dismiss the appeal
not permit evidence to be submitted
bar a party from participating in the appeal
Admission of evidence
The VTE can admit evidence whether or not it would be admissible in a civil trial, but the quality of the evidence will influence the weight given to it.[16]
The VTE can exclude evidence if it:
was not supplied within the required time limit
did not comply with a direction
would be unfair to allow it to be admitted
Legal representation
A party to the appeal can appoint someone to represent them in the proceedings. The representative is not required to be legally qualified. They must not be a member or employee of the valuation tribunals.[17]
Anything permitted or required to be done by a party can be done by the representative, with the exception of signing a witness statement.[18]
When the VTE must strike out an appeal
The VTE must strike out the appeal if it does not have jurisdiction to deal with the proceedings.[19]
The appeal is automatically struck out if the appellant has failed to comply with a direction where striking out is the stated sanction for non-compliance.[20]
When the VTE has discretion to strike out an appeal
The VTE can strike out all or part of the proceedings in other circumstances.
The appellant can apply to have the proceedings reinstated if they were struck out on a discretionary ground.
When the VTE must hold a hearing
The VTE must hold a hearing before making a decision on the appeal unless all parties have consented to proceeding without a hearing, and the VTE agrees it can decide the matter without a hearing.[21]
When the VTE can make a decision without a hearing
The VTE can decide the appeal based on written representations where all parties have consented.[22]
The VTE is not required to hold a hearing to strike out an appeal.[23]
Decision of the VTE
The VTE can consider the merits of a local authority's decision and substitute it for its own.[24]
How the decision is given
The VTE can give its decision orally at a hearing.[25] Once the decision has been made, the VTE must provide to each party:
a written notice stating the VTE panel decision
notification of the right to request a written statement of reasons where they are not supplied
details of the right to appeal or review the decision
details of time limits to request a review or further information
Written reasons for the decision must be requested within two weeks starting with the date the VTE supplied the decision notice.[26]
Tribunal costs
The tribunal service is free. It cannot award costs against either party.[27]
Right to review or appeal the VTE decision
Either party to the appeal has the right to challenge the VTE decision.
Right to review
The appellant can apply to the VTE in writing for a review of the whole or part of the decision.
The VTE President can allow a new panel to review the decision in very limited circumstances relating to procedural irregularity. The VTE cannot review a decision that the appellant or respondent thinks is wrong or unfair.
Right to appeal to the High Court
Decisions on points of law can be appealed to the High Court. This applies if the appellant or respondent believes the VTE did not interpret or apply the law correctly.
An appeal must be lodged with the Administrative Division of the High Court within four weeks of the decision to be appealed.
Judicial review of VTE decision
Where there is no other suitable route of appeal, VTE decisions can be the subject of judicial review in the High Court.
Last updated: 12 November 2025