ASSC Responds to Aberdeenshire Council Visitor Levy

The Association of Scotland’s Self-Caterers (ASSC) has submitted a comprehensive response (view here) to Aberdeenshire Council’s pre-engagement consultation on the proposed visitor levy, calling for a pause on implementation and urging a more considered, collaborative approach to policy development.

The ASSC welcomes the opportunity to engage with the Council on this important matter. However, the organisation continues to oppose the introduction of a visitor levy in Aberdeenshire, citing its likely negative impact on small accommodation businesses, increased regulatory burden, and the threat to regional competitiveness.

Tourism is a key economic contributor to Aberdeenshire, with Scotland’s self-catering sector alone generating £16.6 million in Gross Value Added (GVA) annually and supporting 563 jobs, according to BiGGAR Economics. The ASSC warns that we cannot afford to make the wrong decision, especially amid a fragile recovery and sustained cost pressures facing tourism businesses.

“If a levy is introduced, it must be managed appropriately, mitigating negative impacts and avoiding unintended consequences,” said Fiona Campbell MBE, CEO of the ASSC. “We urge the Council to work with the industry and prioritise practical, fair, and evidence-led solutions.”

While the ASSC recognises that local authorities now have discretionary powers to introduce a visitor levy under the Visitor Levy (Scotland) Act 2024, it cautions against the kind of rushed implementation seen in Edinburgh, where confusion, miscommunication, and reputational damage have followed. In contrast, councils such as South Ayrshire and Comhairle nan Eilean Siar have opted to delay, allowing for a more thoughtful process.

Four Key Recommendations from the ASSC

1. Adopt a Fixed Flat Fee Banded Model
   The current percentage-based system introduces unnecessary complexity, distorts pricing, and imposes heavy administrative demands on self-catering operators. The ASSC strongly supports a tiered fixed flat fee per night, as proposed by the Scottish Tourism Alliance, which offers a simpler, fairer, and more predictable alternative and aligns with international best practices from destinations like Paris and Barcelona.

2. Transfer Collection Responsibility to Local Authorities Using a QR Code System
   Accommodation providers should not be expected to act as unpaid tax collectors. The ASSC recommends a digitally enabled QR code model, used successfully in Venice and Bali, where guests pay the levy directly to the council. This would reduce administrative load, VAT complications, and improve compliance and transparency.

3. Pause Implementation to Avoid Operational Pitfalls
   A delay would allow Aberdeenshire Council to monitor developments in other areas, evaluate unintended consequences, and ensure that any system introduced is both legally and operationally sound.

4. Ringfence Revenue for Tourism Investment Only
   Any funds raised through the levy must be strictly allocated to improving tourism infrastructure and services, in accordance with Sections 13 and 19 of the legislation. This is not a general revenue-raising tool. Transparent governance, including a dedicated Visitor Levy Forum with strong industry representation, will be essential.

Additional Concerns Highlighted by the ASSC

• Impact on Domestic Tourism: Domestic visitors make up 45% of all overnight stays in Scotland. A visitor levy, especially when applied on top of VAT, risks displacing price-sensitive domestic travellers to alternative UK destinations, undermining rural economies that depend on them.
• Small Business Burden: The levy risks pushing small, non-VAT registered businesses over the VAT threshold, creating new tax liabilities and administrative headaches at a time when many are already struggling with increased regulation, energy costs, and uncertain trading conditions.
• Competitive Disadvantage: In contrast to other European countries that have reduced VAT rates on tourism, Scotland’s levy would be stacked on top of a 20% VAT rate and rising travel costs, including a recent 60% increase in the UK’s Electronic Travel Authorisation (ETA) fee. This creates a “tax on a tax” that weakens Scotland’s ability to compete globally.
• Lack of Clarity and Communication: Many residents and visitors are unaware that the levy will apply not only to international tourists but also to locals and Scots holidaying within their own country, including those staying overnight for hospital visits or family events. The Council must provide clear, transparent messaging to avoid confusion and resentment.

Conclusion

The ASSC remains fundamentally opposed to the introduction of a visitor levy in Aberdeenshire under current conditions. However, if the Council decides to proceed, it must:

• Encourage the Scottish Government to adopt a flat fee banded model and implement a QR
  code based payment system that removes the burden from providers.
• Pause current plans until the Scottish Government completes a review and legislative
  amendments.
• Ensure full industry engagement and transparent governance mechanisms.
• Ensure a robust economic impact assessment supports the introduction of a levy, based on
  current data and trading conditions.

“This is too important to get wrong,” Fiona Campbell MBE said. “The self-catering sector generates £864 million in GVA and supports over 29,000 jobs across Scotland. We urge Aberdeenshire Council to act cautiously, collaboratively, and in full partnership with the industry to avoid unintended harm.”

Call to Action: Respond by 22nd July 2025 (extended deadline)

Businesses and stakeholders across Aberdeenshire are urged to have their say by completing the Council’s Visitor Levy Consultation Survey before the extended deadline of Tuesday 22^nd July 2025. The ASSC is encouraging self-catering operators and other affected businesses to highlight the potential unintended consequences of the proposal and to call for a more proportionate, practical and industry-informed approach.

• You can read the full ASSC response here.
• Submit your response here.
• Find out more about consultation developments and other consultation responses here.