VAB13 Adam Haynes

Senedd Cymru | Welsh Parliament

Y Pwyllgor Cyllid | Finance Committee

Bil Llety Ymwelwyr (Cofrestr ac Ardoll) Etc. (Cymru) | Visitor Accommodation (Register and Levy) Etc. (Wales) Bill

Ymateb gan Adam Haynes | Evidence from Adam Haynes

General principles

1. What are your views on the general principles of the Bill and the need for legislation to deliver the Welsh Government’s stated policy objective, which is to:

§ ensure a more even share of costs to fund local services and infrastructure that benefit visitors between resident populations and visitors;

§ provide local authorities with the ability to generate additional revenue that can be invested back into local services and infrastructure to support tourism;

§ support the Welsh Government’s ambitions for sustainable tourism?

(We would be grateful if you could keep your answer to around 500 words).

I am in agreement with the general principle of the tourist tax. However I think the current proposal is both blunt and crude. The legislation needs to be more nuanced and considered.

The Bill’s implementation

The Regulatory Impact Assessment is set out in Part 2 of the Explanatory Memorandum (https://senedd.wales/media/g5ipwvwh/pri-ld16812-em-e.pdf). This includes the Welsh Government’s assessments of the financial and other impacts of the Bill and its implementation.

2. Are there any potential barriers to the implementation of the Bill’s provisions? If so, what are they, and are they adequately taken into account in the Bill and accompanying Explanatory Memorandum and Regulatory Impact Assessment?

(We would be grateful if you could keep your answer to around 500 words).

3. Are any unintended consequences likely to arise from the Bill?

(We would be grateful if you could keep your answer to around 500 words).

Many young people under the age of 18 visit Wales as part of a residential outdoor education visit. Such visits conducted during term time and organised by the school are thus, by definition, an integral part of that person's education. A substantial number of such young people are 'at risk' or could be considered as being vulnerable. Many more are on the SEN register. However these individuals will be still subjected to the tourist tax, in effect such a tax is actually a tax on education. Personally such a situation is one I would have serious concerns about.

                     To tax a vulnerable young person, indeed any child for part of their education is fundamentally immoral.

                     Personally I think children (under 18) visiting on an educational visit with their school and in their term time should be exempt from the tax.               

4. What are your views on the Welsh Government’s assessment of the financial and other impacts of the Bill?

(We would be grateful if you could keep your answer to around 500 words).

The financial consequences of this bill would seem to me to be potentially unfair at best and again immoral and poorly thought out at worst. An outdoor education centre may have 70 beds or more for young people visiting with their school, this could easily result in a bill of £10 000+, which would have to be passed on to the children attending. In contrast a grand hotel with perhaps 10 rooms providing a luxurious stay for their guests may end up with a bill of perhaps only £5000. This really does not seem equitable. How can it be justifiable to tax a wealthy couple enjoying a weekend in a luxury hotel, the same as a vulnerable 10 year old from the centre of Liverpool the same amount?

        A bill of £10 000+ could very easily jeopardise jobs and even the very existence of some centres.

Subordinate legislation

The powers to make subordinate legislation are set out in Part 1: Chapter 5 of the Explanatory Memorandum (https://senedd.wales/media/g5ipwvwh/pri-ld16812-em-e.pdf).

The Welsh Government has also set out its statement of policy intent for subordinate legislation (https://business.senedd.wales/documents/s155951/Statement%20of%20Policy%20Intent.pdf).

5. What are your views on the balance between the information contained on the face of the Bill and what is left to subordinate legislation? Are the powers for Welsh Ministers to make subordinate legislation appropriate?

(We would be grateful if you could keep your answer to around 500 words).

Other considerations

6. Do you have any views on matters related to the quality of the legislation?

(We would be grateful if you could keep your answer to around 500 words).

7. On 26 November, the Cabinet Secretary wrote to the Finance Committee with some indicative additional registration and enforcement provisions (https://business.senedd.wales/documents/s155952/Letter%20from%20the%20Cabinet%20Secretary%20for%20Finance%20and%20Welsh%20Language%20Indicative%20Stage%202%20amendments%20that%20.pdf) he intends to bring forward at Stage 2 of the legislative process (https://senedd.wales/NAfW%20Documents/Assembly%20Business%20section%20documents/Guide%20to%20the%20Legislative%20Process/Guide_to_the_Legislative_Process-eng.pdf).

Do you have any views on the indicative additional registration and enforcement provisions the Welsh Government intends to bring forward at Stage 2?

(We would be grateful if you could keep your answer to around 500 words).

8. Are there any other issues that you would like to raise about the Bill, the accompanying Explanatory Memorandum and Regulatory Impact Assessment, or any related matters?

(We would be grateful if you could keep your answer to around 500 words).

Personal consultation with stakeholders is essential.