VAB20 Snowdonia Hospitality & Lesiure

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 Snowdonia Hospitality & Lesiure  | Evidence from Snowdonia Hospitality & Lesiure

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).

Welsh Government has consistently mislead the public to develop a devise narrative that 'visitors' need to pay their fair share to meet the impacts and consequences of their visits.  This narrative is completely false due to business rates being assessed on turnover within businesses none of which would be possible without the visitor economy.  This includes all visitor types, day or night, business or leisure.  In addition, whilst WGs own draft economic study accepts price elasticity, this relationship can not be certain, as illustrated by the bag tax at 5p which radically changed consumer behaviour, far beyond the monetary amount.  Taxation of over night guests is completely counter to sustainable tourism as is the taxation of children holidaying.

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).

This is a regressive tax on working people and particularly families.  VAT status layers further complexity.  Our business alone will need to request bespoke property management software and double check 20k customer bills.  We will need to ask for proof of ID and age verification for 'children' as age is now significant.  This is a operational barrier.

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).

Displacement of business to non-taxable areas, particularly family holiday makers due to children's charge. Welsh people being taxed to holiday within their own country when they could cross to England and save a significant amount of cost.  There will a devise and unwelcoming message decimated in to communities driving up divisive agendas.  Money will be raised that won't be able to spent within areas as envisaged due to local planning policies.

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).

It is scant and light weight, deliberately orientated for the political purpose of introducing the Bill rather than adequately considering the risks of negative impacts.  It grossly under estimates price elasticity and potential negative impacts and which stakeholders actually carry the risk of any negative impacts.  It relies upon the false assumptions when looking to other territories that have similar charges, specifically failing to properly account for the actual tax landscape Welsh business operate in namely, VAT at 20% for all services, relatively higher Statutory Wage Rates and Business Rates assessed on turnover rather fixed property taxes.

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).

Welsh Ministers have showed a consistant lack of understanding and ability to take account of feedback by those who will bear the legal obligation and any financial negative impacts as stakeholders of The Bill.  Having attended at least 3 WG events with Ministers' present, NOT ONCE has any Minister engaged via Q&A: they have delivered a prepared speech and then immediately left the venue, leaving only Government Officers to field questions.

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).

Enforcement will be patchy at best, poor at worst with only responsible businesses registering.  These business are likely to be already registered for business rates and VAT and therefore registration is just another tier of cost and administration.  Irresponsible business will not be deterred from operating outside the scope of the Bill as amounts of VAPs will easily be saved by non compliance costs, no collection of visitor taxes and registration fee.

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).

The Bill will cost more than it will raise, damage the reputation of Wales in the view of its nearest and largest market, England, whilst failing to deliver anything tangible or that could not already be delivered via appropriate management.  Local community agendas will be able to radically intervene within the local economy for which they bear no liability should those impacts be negative.