The Association of Scotland’s Self-Caterers (ASSC), representing 1,700 members across Scotland, has formally responded to the City of Edinburgh Council’s consultation on the proposed visitor levy. While acknowledging the council’s intent and legislative authority to introduce such a levy, the ASSC maintains its longstanding opposition due to concerns about its potential impact on the tourism and hospitality sectors. If the levy proceeds, it must be managed carefully to minimise harm and maximise benefits for tourism, local businesses, and the wider community.
Key Points from the Submission
- Economic Impact and Justification:
- The levy must be underpinned by a robust economic impact assessment based on current data, avoiding assumptions.
- Consideration for rate flexibility, such as seasonal adjustments, is crucial to balancing economic pressures.
- Administrative Concerns:
- Processes should be streamlined to reduce the burden on small businesses.
- Clarification is needed on how the levy interacts with VAT and other financial thresholds.
- Use of Funds:
- Revenue should exclusively support tourism infrastructure, heritage, and cultural development rather than general city services.
- Transparent governance and public accountability are essential to maintaining trust and ensuring appropriate fund allocation.
- Fairness and Competitiveness:
- The levy should apply uniformly across all forms of accommodation, ensuring a level playing field.
- Consideration for the levy’s cumulative impact alongside other taxes and regulations, particularly during a cost-of-living crisis.
- Stakeholder Engagement:
- Continuous dialogue with industry representatives to address concerns and optimise implementation.
- A clear communication strategy to articulate the benefits to all stakeholders, including visitors.
- Implementation Challenges:
- The proposed start date during peak tourism season is impractical and disruptive.
- Adequate preparation, including systems for collection and refund processes, must be ensured.
- Tourism and Domestic Market Concerns:
- A levy may disproportionately impact domestic tourists, who form a significant share of visitors to Edinburgh.
- Price sensitivity among travellers could lead to a decline in local tourism, shifting demand to other regions.
- Broader Implications:
- Coordination with other councils and consideration for regional displacement are necessary to maintain competitiveness.
- Collaboration with the Scottish Government is urged to address contributions from cruise ships and other areas not currently covered by the proposal.
The detailed response underscores the importance of a balanced, transparent, and well-considered approach to the visitor levy, aligning it with the broader goals of sustainable tourism, the Scottish Tourism strategy, Outlook 2030 and economic resilience.
For advice on responding to Visitor Levy consultations, find out more here.
For latest updates on Visitor Levy proposals, find out more here.
You can read FSB’s response here.
Read the Scottish Tourism Alliance response here.