Company behind “box-shifting” business rates mitigation scheme lodges application with Supreme Court for permission to appeal Court of Appeal setback

Principled Offsite Logistics Limited (POLL) had previously claimed that the scheme saved clients more than £500m in business rates.

The City of London Corporation meanwhile suggested the mitigation method and variants of it were causing it £35m per annum in lost revenue.

The scheme at the centre of The Mayor and Commonalty and Citizens of the City of London v 48th Street Holdings Ltd & Anor [2026] EWCA Civ 970 (29 July 2026) involves POLL placing boxes with redundant contents in otherwise unoccupied premises on a recurrent basis to reduce liability to non-domestic rates by around two thirds.

In May 2025, Charles Bagot KC, sitting as a deputy High Court judge, ruled that POLL’s scheme was lawful.

The City of London then successfully appealed the decision.

The Ministry of Housing, Communities and Local Government subsequently wrote to local authorities responsible for business rates urging them to carry out a review of ‘box-shifting’ schemes in light of the Court of Appeal’s ruling.

See also: Business rates, empty properties and the placement of boxes - Barristers at Landmark Chambers analyse the Court of Appeal’s ruling.