Introduction
The ASSC welcomed the opportunity to respond to the Scottish Government’s consultation in July 2023. The Scottish Government launched this, ostensibly on the issue of second homes and empty homes, yet it brings in an entirely separate property type into the debate: self-catering.
The consultation asks if there should be changes to the definition of when a property offering self-catered accommodation becomes liable for non-domestic rates, which has been dealt with by recent regulations. We have integrated the answers to the consultation questions into our response in this paper which also provides some badly needed context and background information.
Executive Summary
Overall, our response sets out three main themes:
- Underlying the whole consultation process is the crucial need to differentiate between second homes, empty homes and self-catering properties. The ASSC is concerned about the conflation between the three types of property and that self-catering may once again be unfairly targeted for longstanding housing challenges when a more holistic approach is required.
- The ASSC do not believe that the thresholds for self-catering accommodation for non-domestic rates should be changed. We believe there is an insufficient evidence base to make further changes to the Non-Domestic Rates (NDR) regime for self-catering. We supported the Barclay Review process and its recommendations and do not understand the rationale for seeking further changes at this time when The Council Tax (Dwellings and Part Residential Subjects) (Scotland) Amendment Regulations 2021 were introduced in April 2023 and the first audit of NDR subjects is underway. It is premature to make further regulatory changes prior to the outcome of this review.
- Self-catering faces a disproportionate regulatory burden, from issues including short-term let licensing to planning policy, and is often used as a convenience scapegoat for longstanding challenges relating to housing. We would support measures that tackle the increase in empty homes and second homes, which unlike self-catering, do not provide an economic and social boost to local communities through visitor spend.