Summary
ASSC undertook a survey, in order to inform greater discussion regarding the support required for self-catering operators in Scotland to ensure that no sector is left behind by government, as well as what changes are necessary to protect livelihoods in what has been a key component part of Scotland’s tourism offering for a generation.
Some of the key findings include:
Updated data in 24 hours from 21st April
601 responses in 23 hours
411 68% have still received no support
91 15% have received a £10k grant
1 0.17% have received a £25k grant
11 1.4% have had applications rejected
The remaining respondents are confused as to the eligibility criteria and have not applied.
With different local authorities behaving completely differently and asking for different hoops to be jumped through, why should geography dictate the amount of added stress that we are all going through at this time? See below for some case studies.
Case Studies
Case Study 1:
“Thank you for your e-mail regarding the information regarding what is now required after already filling in the application form more that 10 days ago on the 7/4/20. I have in fact been looking everyday for the grant money to go into my account, of which all the details were all given including my RBS business bank statement.
I am sure the department is aware that this is a total lifeline for me to stop my actually going under, I have put all my bills and loans on hold and I am now in arrears.
Sorry to be so blunt but I have only very limited funds to live on now £231.62 I cannot stress how important that this government grant aid is paid at the very soonest opportunity to my account.” Anon, Moray Speyside
Case Study 2:
“I have just had my application for the £10k grant summarily dismissed by Argyll & Bute Council. I am self-employed. My FHL receipts for 2019/20 represent 22% of my overall receipts and as such represent a significant proportion, without which I am not financially viable. A&BC quoted to me that my FHL receipts should constitute “a primary source of earnings (for example, one third or more)” and they have rigidly interpreted the 33% rule in rejecting my application. Clearly 22% is very significant and does represent “a primary source” but they have simply and arbitrarily used the 33% figure without recourse to common sense or their own wording “a primary source” not the primary source.
“Similarly on the occupancy rate they have made an arbitrary ruling. I reminded them that to qualify as a trading business under HMRC’s FHL tax rules, a property must be available for let for a minimum of 210 days and actually let for a minimum 105 days in any year. Furthermore, as occupancy can be very variable from one year to the next, depending on economic conditions, weather and many other factors, HMRC allow averaging in meeting these criteria rather than confining it to one arbitrary year. My business has been running for 13 years and I have met the HMRC criteria on availability and occupancy throughout this period.
“I believe that hotels and B&Bs have not had an occupancy criterion applied, and shops have no requirement to prove how much stock was sold during the year – indeed they don’t even have to prove they were open and available to trade, so this seems to be a deeply, negatively discriminatory criterion to apply to self-catering.
“In my case, for 2019/20 the availability was 365 days and the occupancy was 119 days, which I gave hard evidence for. I asked them that given HMRC’s pre-existing rules on FHL and the comparison with hotels, B&Bs and shops, I sincerely hoped they would deem this occupancy record sufficient for the grant to be approved. However again, they stuck rigidly to this arbitrary figure of 140 days, even though there seems to be no logical precedent for that figure.
“This is deeply disappointing. My MSP has been of no help whatsoever and government ministers I have written to have not even bothered to reply.
“Is there any prospect of these arbitrary rules, and their rigid interpretation, being relaxed so that self-catering can be treated on an equivalent basis to other small businesses?” Holiday Cottages, Argyll & Bute
Case Study 3:
“We run a diversified rural business and farming represents the majority of our turnover and our more recent holiday cottage business has not yet reached this 1/3 threshold as apparently required by the Holyrood Administration. Has there been any indication that this arbitrary 1/3 rule been removed?
“We have one unit in a different local authority from our main business here in Wigtownshire (Dumfries & Galloway Council). Have you heard of one Council rejecting claims for 75% payments for second units in different council areas?” Holiday Cottages, Dumfries & Galloway
Case Study 4:
A small business grant application is not being accepted unless additional evidence is provided on the following grounds:
“To enable me to process your application I require you to provide a copy of your self-assessment tax return summary page (we will accept your 2018/2019 tax return) and also confirmation of your weekly letting charges in respect of *** Cottage.
For self-catering premises I also require you to confirm that receipts represent a primary source of earnings (e.g. one third or more) – Yes/No
The property has been let out for 140 days or more in financial year 2019/2020 – Yes/No
Regarding claiming a grant in respect of a second property we are awaiting further guidance from the Scottish Government on this matter. Any further guidance will be provided on the Council Website at www.dumgal.gov.uk”
Facts in defence of this application:
In England, this business would be eligible for two £10,000 grants, reflecting that they are two going concern businesses, and appreciating the loss of income associated with the Covid-19 outbreak. ASSC Director, Dumfries & Galloway