Tax Law · Upper Tribunal (Lands Chamber)
Nicola Johnson v The Salvation Army Trustee Company
Checked against the judgment on 2 October 2026 · how we verify
Facts
The respondent, the Salvation Army, is an organisation responsible for the conduct of public religious worship. Its former headquarters at 101 Newington Causeway, London, was a ten-storey building that housed up to 500 staff. It was agreed that most of the building was used as offices on the material day, 1 April 2017, and was exempt from non-domestic rating under paragraph 11(2)(b) of Schedule 5 to the Local Government Finance Act 1988. The dispute concerned three rooms. The first was a large ground-floor Hall seating about 172 people, with a dais, crosses, a lectern and a drum kit. Staff booked it for meetings, training, presentations and town hall events, and it was also used for weekly prayer meetings of usually no more than an hour and for the Christmas Carol Service. The second was a small ninth-floor Prayer Room, open to all staff of any faith for private prayer and reflection. The third was a kitchen. In a decision of 12 November 2025, the Valuation Tribunal for England held that the Hall and the Prayer Room were used for purposes ancillary to office use and were exempt. On the respondent's concession, it held that the kitchen was not exempt, although the parties now agree that it is. The Valuation Officer appealed to the Upper Tribunal (Lands Chamber) about the Hall and the Prayer Room. The parties agreed alternative rateable values ranging from £1 to £57,000.
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