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 Berin Jones | Evidence from Berin Jones
(We would be grateful if you could keep your answer to around 500 words).
The general principles are based on the need for extra funding to support local services and the view that it happens in other countries, however the Tax regime in those countries is far more favourable towards the Tourism sector so it has a balancing effect . In Britain the Tourism industry already pays 66% of its income to the government in one form of tax or another so this levy is likely to cause major collapse of employment and disuse of historical buildings in the Nation. The major impacts stated as needing support are those caused by DAY Visitors and not those who stay overnight in our nation and support the local employment and economies. Tax those who already pay tax and they stop coming as has been experienced in Pembrokeshire.
Existing businesses pay Business rates as well as Residential Council Tax for the residential properties they live in as well as Corporation Tax and VAT so they already pay a fair share of the costs to fund local services and infastructure so the principles of the Bill are based on innaccurate perceptions and the introduction of a Levy has not been effectively assessed for it's impact on the industry. As a person employed in the industry I am deeply concerned at the lack of understanding by the Government as to the essential role it plays already and the risk it currently faces of total collapse.
Local Authorities don't provide anything specific to support Tourism over and above what the industry does to support itself so clear plans for Tourism need to be developed by each authority to prove the need for additional revenue for this area. Just reporting after the fact is not acceptable.
The Welsh Government has not published a detail plan for Sustainable Tourism so how can it be justified as a reason for imposing an additional Tax on those who already pay to stay overnight in Hotels and Guesthouses. This levy will have no impact on day visitors and there is no structure to charge the vast numbers of camper vans and motorhomes that descend on the local communities and don't stay in businesses overnight and there is no provision to charge these criminals in the Bill.
Deciding to make sectors exempt because they are perceived as too difficult to gather the levy from is discriminatory and introduces confusion to the customer.
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.
(We would be grateful if you could keep your answer to around 500 words).
The bill fails to recognise the costs associated with collection for businesses which need to be supported especially with the increased labour costs faced by all businesses.
The failure to register ALL locations that provide overnight accommodation is a serious failure and discriminatory element of the Tax, such as farmers with fields turned over to camping for 28 days a year, and residents who are permitted by law to rent out a room in their homes for 28 days without tax liability. The vast numbers of motorhomes and camper vans are also not going to be taxed as they park wherever they like, including on highway laybyes etc and the introduction of a levy on the legitimate accommodation providers will result in a greater number of people seeking out and using unregistered and unwanted locations to camp as has already been seen in Eryri. The bill also fails to address the vast number of day visitors who do not stay overnight in any location and have a major impact on the infastructure of our communities as they travel from across the border to enjoy our countryside only to return home that evening, not having spent any money in our communities. These numbers will only increase as a result of pricing accommodation providers in Wales out of the market and resulting in more of us being made redundant as businesses are no longer viable.
(We would be grateful if you could keep your answer to around 500 words).
Yes, unemployment will increase in our rural communities that depend upon the visitor economy to survive and maintain the existing life of the community and Welsh Language. No great industries are going to move in to our rural communities to fill the gap left by a decline of Tourism and so our own people will be forced to move away from their communities in search of employment resulting in yet more abandoned properties and the decline of the Welsh Language.
(We would be grateful if you could keep your answer to around 500 words).
Very simplistic and not based on a deep analysis of the genuine economic impact likely to arise as has been seen by the impact of the introduction of the 182 rule and 300% of highest rate Council Tax band that has resulted in Pembrokeshire having to backtrack on it's decision to introduce what Welsh Government perceived through 'economic impact assessment' as being sustainable. The impact assessment also did not make any consideration to the increased Labour Cost faced by the Tourism industry after the recent Budget resulting in significant job losses and declining demand from visitors for accommodation due to price.
There also appears to have been no in depth assessment of what is causing the perceived impacts that a levy is alleged to provide funding to support which means that there is no clear understanding of whether the levy is being applied to the right people.
The assessment fails to consider the impact on the decline in Welsh Language as a result of the loss of income to those who depend upon the Visitor economy to support them remaining in the community, such as Plumbers, Electricians, Cleaners, Builders, suppliers of Welsh Produce and shopkeepers who depend upon the increased trade during the summer period to sustain their existence in winter. The assessment focusses on the Tourism industry in isolation of the greater and far wider impact imposing the Levy and over regulating it will have
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).
(We would be grateful if you could keep your answer to around 500 words).
The powers proposed to be given to the Ministers under the subordinate legislation should not be granted as these provide the Ministers with the ability to override the local authority and set levy rates without any substantive Economic impact or community impact assessment prior to making these decisions. Additionally providing ministers with the power to determine whether an industry sector should be given exemption from the levy provides an opportunity for inappropriate lobbying from certain sectors to the detriment of the wider industry. Either all places that a person stays overnight within a Local Authority Boundary have the Levy imposed on them or None. Providing powers to impose or remove business sectors from the levy will be detrimental to the revenues gathered as the customer will move their money to where they pay less to the detriment of the sector already being discrminated against by having to pay the Levy. It removes simplicity and clarity and introduces complexity and confusion, which is against the principles of the Bill.
(We would be grateful if you could keep your answer to around 500 words).
It is poorly put together, with no economic or community impact assessment nor does it sufficiently evaluate the loss of economy and it's impact on the Well Bing of Future Generations as they are forced to leave the communities they are born in to due to the loss of employment opportunities. It makes generic statements with little or no hard factual basis to the statements made. It has clearly been generated with a single Party involvement and has not been created with the balanced views of all Political Parties in the Sennedd so is failing to be a National Policy but a Political policy to discriminate against a single industry sector making it accountable for the impacts of all industries in a Local Authority area. Visitors are not the only users of the roads and bins in our communities yet this legislation would have you believe that they are.
(We would be grateful if you could keep your answer to around 500 words).
Evidence has shown that the introduction of a Landlord residential scheme led to the introduction of a Licensing scheme which has driven poor quality residential landlords underground as well as resulting in massive Homelessness across the nation. This is how well the wider impacts of perceived Controlling measures deemed essential by The Sennedd actually work towards achieving the perceived end result. Now we have more people facing homelessness in our communities because the 'Enforcement' of ill thought out Legislation and failure to understand the economics of the sector result in the opposite to what you seek to achieve. Enforcement is the wrong thing to do and will further destroy the faith in government of the industry, placing a bigger divide between the legislators and the industry.
The real effective way to control how much of the nation becomes used by Tourism is to introduce effective Planning legislation that makes it illegal to rent out properties not deemed to be beneficial as Tourist locations. this legislation is attacking the symptoms and fails once again to truly confront the Root Cause.
(We would be grateful if you could keep your answer to around 500 words).
Wales is a Nation that stretches form it's border with England in the North all the way to the South as well as it's border with the Severn estuary and Irish Sea. It is not just Cardiff and the South Wales valleys, so those who are creating the legislation need to get out across the nation to see what is truly happening and the immense benefits communities across the less populated parts of the Nation get from Tourism before making the decisions about it's future that they are making. Having been born and brought up in this great nation I feel sickened by the prospect of unemployment and local community loss this legislation will result in. Those I grew up with are all scared of the impact of this legislation as they face ruin through there being a significant decline in trade in the face of ever increasing costs that result in the critical Hospitality industry not having the finances available to invest in to the local community and therefore they get no demand for the services they provide resulting in them also having to leave the area they were born and brought up in. This isn't seen in Cardiff as it has a totally different community and economic platform.
Before it is too late, For the Sake of our Future Generations, put a stop to this discriminatory behaviour towards the Hospitality and Tourism Industry.