Opinion: A Tourist Tax is too Important to get Wrong

Despite objections from Scotland’s vital tourism industry, the Scottish Government has made it clear that it wishes for local authorities to have the power to place a levy on visitors to their areas in order to raise revenue.

Although plans have been put on hold during the Covid-19 pandemic, there remains much discussion about the pros and cons of a Tourist Tax. A tourist tax now appears to be inevitable.

The ASSC believes that a tourist tax will have a negative impact on Scottish tourism and the Scottish economy. We worry that by charging our treasured visitors we will put a damper on their visits here which poses a real threat to our continued prosperity. We are still adamantly against the idea and believe it would be better if it never saw the light of day.

However, while we hold all this to be true, Scottish tourism is an industry that thrives on being realistic and cooperating as broadly as possible. We believe that we have a unique insight into how this unwelcome levy can be applied to ensure that it is as fair and useful as possible.

Firstly, the competitiveness of our sector must be protected. Scotland currently sits at the bottom of the league in terms of price competitiveness (140 out of 140 countries).

We also have a comparatively high rate of VAT, sitting at 20% – which will also be applied on top of the tourist tax.

These roadblocks, plus the fact that much of Scottish tourism comprises of small businesses and individual and family operators, means that we are already in a precarious position regarding keeping our wonderful tourist offering competitive and therefore must tread carefully with this levy.

Secondly, we need to keep it reciprocal and transparent. On top of the fact that most visitors to places like Edinburgh or Skye, which have been at the centre of the on-going debate over the impact of tourism, come from within the UK so we are in essence charging ourselves an additional tax with this levy, we need to ensure that the money raised from a tourist tax is spent locally to improve services for residents and visitors alike so that those impacted by the charge see real, lasting, and tangible evidence for its continued imposition.

Thirdly, and perhaps most simply, a tourist tax requires sufficient notice to be given of any changes. We would recommend that, in order to protect the industry and those whom it serves, any changes be given at least 18-24 months’ notice before they are applied, after the legislative process is complete. The reason for this is equally simple; the costs of any such change that is given less than this length of preparation time will inevitably be passed on to consumers as business will not have the time to accommodate it. It is for this reason that we recommend that, should the current legislative timeframe hold, no local authority use their tourist tax powers until at least 2023.

Fourthly, naturally, as a major stakeholder and contributor to Scottish tourism, we call for the process of implementing the tourist tax to be as consultative as possible. Local authorities should consider their local industry representatives, communities, and present national level industry bodies to be partners in a process rather than adversaries or competing interests. We all want flourishing communities with top grade services provided for residents and visitors alike and so we must work together, even on this divisive issue, to ensure that’s what we get.

Finally, the successful implementation of any form of tax depends largely on how it is paid and collected. For this reason, the tourist tax must be easy to pay, collect, and process, both for visitors and tourism operators, to ensure as frictionless an application as is possible. This, while appearing obvious, may be the most difficult aspect of this policy to get right and may also turn out to be its biggest test; one which it has to pass but, in reality, will find it very difficult to. The only way to manage and audit such a levy relies on a specifically designed registration system that captures all accommodation models.

Most of all, innovation must be at the core of the approach going forward. If, as the National Strategy vision calls for, Scotland is to be the world leader in 21st century tourism, then any levy must be implemented in an innovative, creative, and world-leading way and not just a ‘digital framework’ as others have done. Moreover, this innovation must also include consideration for different parts of Scotland. For instance, a levy on overnight stays may work in Edinburgh but will do nothing to address the problems faced by other parts of the country. If we’re going to have this potentially damaging measure then it must be innovative enough to negate those risks and find a solution that works for everyone.

BBC Scotland interview, 19th April 2021.

Fiona Campbell

Chief Executive

Association of Scotland’s Self-Caterers

Answers to Key Questions (first published 24th March – updated 22nd April)

From 26 April, the tourism and hospitality industry can begin to reopen.

There are, understandably, some pertinent questions you need answers to, and we’ve worked with the Scottish Government team and VisitScotland to pull together a list of questions, and answers:

Guidance / policy

 Q: The current guidance online doesn’t reflect the announcement on 16 March for easing of restrictions – is this now out of date?

A: Guidance that will take effect from 26 April is currently being finalised and is hoped will be available from around mid-April. The guidance currently online reflects the current regulations, which for the most part of tourism and hospitality means facilities are closed in level 4. Much of the material relating to assessing risk and workforce issues will remain the same however, so operators can start to review their risk assessments on key issues around physical distancing and hygiene protocols in preparation for checking against any additional requirements when updated guidance is published.

Accomodation

Q: For accommodation: when can I take bookings?

A: Tourist accommodation is expected to re-open from 26 April, at which point travel restrictions across mainland Scotland (into and out of a level 3 areas) will be lifted. Accommodation is closed to general tourism until then.

Q: Can I stay in my own second home from Friday 16th April?

A: The travel relaxation allowing travel outwith own LA for is for family and friends socialising and exercise only does not allow overnight stays.

Households

Q:  Can we host more than one household in our self-catering property? 

A: This will depend on the capacity of the accommodation, and the stage we are at in the coronavirus timetable for easing restrictions: Coronavirus (COVID-19): timetable for easing restrictions – gov.scot (www.gov.scot).

It is expected that tourist accommodation will reopen on 26 April (self-catering accommodation to be restricted in line with rules on indoor gathering).  The prohibition of in-home socialising will apply due to the increased transmissibility of the new variants, but will continue to be kept under review at this date.

The rules for self-catering (including overnight stays) are in line with the private dwelling socialising rules as set out in the levels framework.

From 26 April – guests from one household can stay overnight in self catering.

While the host is at home (eg Airbnb homesharing: Single household only until the levels permit sharing (within capacity and agreed numbers), and then with all appropriate mitigations (own bedroom) and enhanced hygiene. So 17th May is the date for homesharing to re-open.

Indicatively,  from 17 May – four guests from two households can stay overnight in self-catering (in line with ‘up to four people from two households can socialise indoors in a private home or public space’).

This is either 4/2 or a single household.  If you have a large household (more than 4 people) you can’t add anybody else.  The only exception would be if they are in an existing support bubble with the main household.

“If circumstances permit, I can confirm that it would be the intention to move to level 1 on Monday 7 June, before then I hope moving to level 0 in late June – and then as we go into the deeper part of the summer, to something much more like normality, over the course of July.” First Minister

Indicatively, from 7th June – Up to 6 people from up to 3 households can stay in self-catering accommodation.

Indicatively, level zero by late June – Maximum of 8 people from up to 4 households.

Children 12 years and under not included.

Q: What is an extended household?

A: An extended household is a support network which joins two households.

You can form an extended household with another household of any size if you:

  • live by yourself
  • are a single parent
  • are part of a couple who lives apart – including any children you each live with

Definition of an extended household.

Operators are advised to ensure there is sufficient capacity with their accommodation to safely accommodate the numbers of people and households permitted in the levels framework.  It is advisable for separate households to have their own bedrooms within shared accommodation, that shared bathrooms and kitchens are kept clean and materials and instructions for these are provided.  Visitors should, where practicable, use shared rooms one at a time with cleaning and ventilation in between (e.g. preparing and eating a meal).  Where communal toilets are being used providers should implement measures to decrease the risk of contamination including enhanced cleaning and consider reducing access to a one in, one out basis.  Cleaning materials should be provided for users to ‘clean as they go’.

The approach to reducing household restrictions will be gradual as we move through the levels to ensure continued suppression of the virus. We will keep the guidance around restrictions under review to ensure safety, but will not keep them in place longer than is necessary.

Q: Test and Protect – do I need to collect details of all adult guests?

A: No. See more here.

Travel restrictions

Q: Can those who live in Scotland travel anywhere in Scotland and stay in hotel for recreational purposes from 26 April?

A: Yes. Travel within all of mainland Scotland is expected to be permitted from 26 April (subject to other restrictions that remain in place such as household restrictions).  There may be different rules for Island communities – further information will be made available in due course.

Q: Is it possible for people to travel to and from Scotland from other parts of UK and stay in hotels for recreational purposes from 26 April?

A: This is still to be confirmed. In March the First Minister said “We hope that restrictions on journeys between Scotland and other parts of the UK and the wider common travel area can also be lifted, if not on 26 April, then as soon as possible thereafter. However, we need to keep this under review, as part of our efforts to reduce the risk of new cases being imported into Scotland and we will update the position during April.”

Q: When will international travel be able to resume? 

A: This is still to be confirmed.  Governments across the UK are working together to determine the right approach for international travel and further updates will be provided in due course.

Q: Can people travel to Scotland from England to re-open businesses for 26th April?

A. Travel is currently permitted for essential reasons, so reopening a business would fall under an exemption.

Visitor attractions

Q: When can visitor attractions open?

A: Visitor attractions are expected to open from 26 April, subject to socialising and physical distancing rules, and risk assessed covid safe protocols.

Q: While museums and galleries are mentioned being allowed to open from 26 April, what about other types of visitor centres?

A: Mainstream visitor attractions are expected to open on 26 April.  Facilities like funfairs and soft play areas are not classified as visitor attractions for the purpose of the 26 April opening and are subject to separate guidance which will support level 1 sectors, approx. June opening.

Other Questions

Q: What happens If a local authorities case number go over 150/100000, will they revert to level 4, closed and not allowed to travel, or welcome guests?

A. The updated Strategic Framework published on 23 February describes a process of phased, prioritised national easings. In step with these changes, we committed to undertaking a review of the state of the epidemic and our response to it, to ensure that it remains safe to proceed with each new set of easings. To inform these reviews we have adopted the six criteria recommended by the World Health Organisation[1] in assessing whether it is safe to proceed. Consistent with our commitment to transparency in decision making, we intend to publish the assessments made, in order to explain our decisions.

While this is a national level route map, as the First Minister set out last Tuesday, this doesn’t preclude us from making use of a localised levels-based/local lockdown approach if this is deemed justified, necessary and proportionate.

Work is underway to finalise the methodology for applying the Levels framework on a more localised geographic basis should this be needed in the future, including the way in which indicators and other intelligence feed into this.

Q: Can weddings take place in self-catering units? 

A. Our current thinking is that if there is a manager on the premises checking that physical distancing etc is being complied with, we might treat them in the same way as a hotel venue. However, if there is no such manager, then we would treat them in the same way as a private dwelling.

Business Support Funding

Q1  Will businesses on Council Tax, which are currently eligible for the equivalent of SFBF, be eligible for continued support via SAP-CTF until we leave Level 4 on 26th April as previously announced?

A. We can now confirm that additional funding for the Small Accommodation Providers paying Council Tax fund. Funding is to be increased by approx. £14.45m, enabling eligible B&Bs, small guesthouses etc. to receive a SFBF April payment of £1,000 and a Restart Grant of £8,000. You can find out more detail here.

Q2. Will self-catering businesses on islands impacted by travel restrictions receive continued financial support?

A. Steps have been put in place to ensure that equivalent funding to the SFBF and other programme, such as SAP-CTF are also available on the islands. Anything additional will be at discretion of the islands authorities themselves, via use of their own Local Authority Discretion Fund.

Q2  Will self-catering businesses that continue to be impacted by household restrictions be supported by ongoing financial support until they are able to trade ‘normally’?

A. We have already supported larger self-catering businesses through the large self-catering grant (2k), and exclusive use venues with the exclusive use grant (10k) .  Due to the limits on budgets available, there are no plans to rerun this fund. If they are registered for Non Domestic Rates and in receipt of Strategic Framework Business Fund then they will receive a restart grant in April of up to £18k plus a supplement of up to £1,500.

With the increased transmissibility of the new variants of the virus single household restrictions are necessary, at least in the initial phases of a move out of lockdown.  The approach to reducing household restrictions will be gradual as we move through the levels to ensure continued suppression of the virus.  We will keep the guidance around restrictions under review to ensure safety, but will not keep them in place longer than is necessary.

“We will continue to monitor and review the appropriateness of our business support packages as we move out of lockdown. You will of course recognise that this is a continuing moving environment and we aim to keep the business community updated as quickly as decisions are made. I trust that in the meantime this information is helpful.” Cabinet Secretary for Finance, Kate Forbes MSP

 

 

ASSC Talks: Taking a Break

We are taking a short break from our regular Talks until the 25th May but rest assured we will be back and if we need to arrange a Talk in the coming weeks to update you on anything we definitely will do so.

Please keep an eye on our regular Newsletters and remember that we have a fantastic library of guidance notes available.

We’d like to thank you all for supporting the ASSC Talks over the past few months and wish you all the best of luck with re-opening next week (if you can). Even if you feel anxious, and I am sure you may well do, stay calm, take deep breaths. You can do it!

from the ASSC Team: Fiona, Eleanor, Mel & Joyce