Salvation Army prayer rooms exempt as ancillary to offices

The Upper Tribunal (Lands Chamber) has dismissed a Valuation Officer's appeal over business-rates exemption for two roomsNationalarchives in the Salvation Army's former headquarters at 101 Newington Causeway, London, holding that a large meeting hall also used for weekly prayer and a small prayer room were both used for purposes ancillary to office use and therefore exempt under Schedule 5 to the Local Government Finance Act 1988Nationalarchives.

The decision of 1 October 2026Nationalarchives, in Nicola Johnson v The Salvation Army Trustee Company [2026] UKUT 370 (LC), concerned the position at the material day of 1 April 2017, when the ten-storey building accommodated up to 500 staff. It was common ground that most of the building was used as offices and exempt under paragraph 11(2)(b) of Schedule 5. The dispute concerned a 180.78 sq m ground-floor hall and a 9.49 sq m ninth-floor prayer room. On the agreed valuations, exemption of both rooms leaves the rateable value at £1; exemption of neither leaves it at £57,000.

On the law, the Tribunal rejected both a "reasonably liberal" construction of the exemption and the Valuation Officer's argument that ancillary use must be "generic" office-type use found in any office. Ancillary means subordinate, supplemental or incidental to office use — toilets, kitchens and serveries are uncontroversial examples — and paragraph 11 gives no closed list of ancillary uses. What matters is whether the respondent uses the room for purposes ancillary to its own office use of the rest of the building, not whether other offices have similar facilitiesNationalarchives. The Tribunal also rejected the argument that use for private worship automatically disqualifies a room: exempting prayer space that is ancillary to office use does not create a back-door exemption for private worship, because the statute asks only whether the use is ancillary.

On the facts, the hall looked like an informal church, with a dais, crosses, a lectern and a drum kit, and hosted an hour of weekly prayer plus Christmas carol services. But uncontested evidence showed it was booked by all staff for meetings, training, presentations, town halls and fire-evacuation training, and was used for those office purposes far more than for prayer. Its primary use was therefore agreed ancillary office useNationalarchives, and its large size — seating about 172 against a 500-strong workforce — was immaterial. The additional prayer use did not change that character.

The prayer room, with a low table, chair, cross and "Prayer Wall", was open to staff of any faith at any time without booking for personal reflection or prayer. The Tribunal treated whether it was a neutral multi-faith space as a distraction: the evidence was that it was provided for staff well-being and used by staff, making it no less ancillary to office use than the kitchen. The appeal was dismissedNationalarchives, with costs directions to follow if not agreed.

Legal basis: Schedule 5, paragraph 11(2)(b) to the Local Government Finance Act 1988; Church of Scientology Religious Education College Inc v Ricketts (VO) [2023] UKUT 1 (LC) on office use.