ASSC attended a pre-consultation industry workshop in July, which gathered views from the industry and allowed the Council to design their consultation in such a way that the key issues raised are included amongst the survey questions.
They were keen to hear the views of a wide cross-section of Highland residents, businesses and visitors on whether such a scheme should be used in Highland and, if so, how.
In parallel with this they also contracted the Moffat Centre for Travel and Tourism Business Development at Glasgow Caledonian University to undertake face to face surveys with Highland visitors. Both surveys close on 20th October 2019.
The survey, and a short video, which picks up the main points from the presentations given at the workshops and key issues raised by those attending can be found at gov.uk/TVL
They have also produced an anonymised summary of the points raised during these sessions which is now available alongside the survey and video – or you can download it directly here.
ASSC has issued the following Tourist Tax Consultation Brief:
The administrative burden of a tourist tax across different accommodation models would be disproportionate.
Hotels would be able to implement technological changes in order to add the charge on to invoices. This would potentially cost thousands of pounds in the first instance, however, thereafter would be fairly simple to administer.
Administering a tourist tax across the STL sector will be hugely difficult to design and implement, let alone audit.
There are multiple accommodation models within the short-term let sector alone.
Whilst some of the collaborative economy platforms may be able to simply add a charge on booking and take it at source, this may not be the case for other platforms.
It is simplistic to assume that all short-term rental operators use Airbnb as a route to platform. For the independent operator, the administration of a tourist tax may not be ‘simple and easy’.
Many operators simply do not have the technology to implement it. Would the operator take cash form the guest? Would they personally deliver it to the Council? Many do not generate invoices, so would struggle with the technological administration of such a scheme.
Adding percentage fees retained by providers adds to the administrative burden.
The auditing of the scheme should be considered carefully, in terms of fairness and to counter avoidance. However, this may prove difficult across smaller accommodation providers.
There is currently no registration system for accommodation providers, so it may prove almost impossible to police the scheme, rendering it unfair and incompetent.
It is impossible to achieve the ambition of a tourist tax being ‘fair and simple’.
Any variations in level of the charge could result in lack of proportionality and hinder “a simple administrative system that is easy to operate and cheap to run”, as set out in the City of Edinburgh consultation process.
In terms of applying the tax on a per room basis, this will be difficult to implement in different accommodation models. How would it apply to youth hostels with multiple beds per room / single occupancy in a two-room apartment / rogue operators who over- occupy properties?
A seasonal charge would exacerbate the administrative burden of a tourism tax.
Is the income worth the investment to implement the scheme properly and efficiently?
A tourism tax is not intended to fund core services. A tourism tax should support the key priorities set out by The Scottish Tourism Alliance’s Tourism Scotland Strategy 2020.
Any investment should be able to be measured, and the impact clearly identified.
There has been no economic impact assessment of how a tourist tax would impact on visitor spend / businesses administrative costs / local authorities to implement.
The potential reputational damage it may have to Scotland and visitors’ perception of our ‘welcome’.
It should not be a solely a ‘bed tax’, which will penalise overnight visitors, while excluding letting day visitors. Several sectors should contribute to any levy.
Alternative approaches to a levy should be considered reflecting a diverse range of requirements across the 32 local authorities: car parking charges, number plate recognition, events and festival tickets etc
73% of ASSC members are opposed to a tourist tax.
In rural areas with plenty of capacity, operators are not able to charge city rates or let by the night.
If rural businesses are forced into increasing their prices further that it could seriously damage these small businesses.
There is a finer economic balance in rural parts, especially in remoter areas.
Proponents of a tourism tax frequently assert that they successfully operate in a number of European cities, while simultaneously failing to acknowledge the high rate of VAT applied to our sector.
In uncertain times, with Brexit on the horizon and many sectors anticipating a downturn, bringing in an additional tax at this stage would potentially be negligent.