The Mayor and Commonalty and Citizens of the City of London (Appellants/Claimants) v 48th Street Holdings Limited and another (Respondents/Defendants)
Wednesday 15 – Thursday 16 July 2026
By Appellant’s Notice filed on 12 June 2025 the Claimant appeals against the order of the High Court dated 15 May 2025 dismissing the claim and ordering to pay the Defendants’ costs.
The case concerned the validity of a business rates mitigation scheme used by 48th Street Holdings Ltd and operated by Principled Offsite Logistics Ltd (POLL), under which POLL temporarily occupied otherwise vacant commercial premises for six-week periods by storing boxes with redundant contents.
The occupation was intended to trigger successive periods of exemption from empty property rates, substantially reducing the landlord’s liability. The City of London Corporation challenged the scheme, arguing that it was an artificial tax-avoidance arrangement that lacked any genuine commercial purpose and therefore fell outside the statutory scheme when interpreted purposively in accordance with the Ramsay principles.
The court rejected that argument, holding that the scheme was lawful and that the occupation satisfied the established requirements for rateable occupation.
View Hearing:
Day 1
Day 2