VAB49 Llandudno Hospitality Association

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 Cymdeithas Lletygarwch Llandudno | Evidence from Llandudno Hospitality Association

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).

The Bill is unnecessary. Tourism is largely self funding through taxation of tourism providers by way of Business Rates, VAT, Corporation Tax, Income Tax, NI, Employers NI and Alcohol Duty. In other countries which charge a Levy, the VAT on tourism is generally 10% or less. To introduce this charge unilaterally in the UK will drive custom to other parts of the UK. Tourism is essential to the Welsh economy.

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).

A register of Businesses providing accommodation will ensure a level playing field for Hospitality businesses. The register needs to be cheap and simple to use and comprehensive in its scope. If all providers need to register, that is all that is needed. They can file their information on-line to be accessed by all relevant, government agencies. There is no need for a Licensing Authority. Anyone found to be trading without registration could be sanctioned without the cost of Licensing being imposed on other Providers and Local Authorities.

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).

Implementing the levy in Wales alone would inevitably be detrimental to the Tourism Industry in Wales. This would impact directly on the Welsh economy. This policy needs to be UK-wide and taken in conjunction with VAT and Business Rates. European VAT on tourism is generally much lower. Hospitality is land-hungry by its very nature and incurs disproportionate Business Rates as a result. Further Taxation of this sector is unfair and destructive, especially when done in isolation.

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).

Wrong. The Bill is detrimental to tourism and therefore the Welsh economy. Charging overnight guests to pay for day-tripper problems is wrong and will be seen as such by the public who will vote with their feet. Taxing an already over-taxed sector is destructive. Tourism is treated as a cash-cow rather than "The Goose that lays the Golden Egg." Kill the Goose; no more eggs.

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).

Subordinate legislation for this bill needs to be kept to an absolute minimum. Powers to Ministers are inappropriate. There is a danger of escalating the Register to a Licensing System which will cause unnecessary expense to businesses and Local Authorities alike. Authorities do not have the means to control or regulate new legislation. Businesses in the tourism sector are still recovering from the effects of COVID controls and cannot afford any further impact.

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).

The legislation seems to be driven by ideological views rather than a need. It leaves far too much work to Local Authorities which cannot afford to effectively assess the imact on their economies. This should have started with an impact assessment. The potential effect on the economy is unknown yet the Bill has been passed and the "buck" has been passed to Local Authorities. Some will implement in line with the same dogma as followed by the Senedd. Others may lose out by being forced into enacting this legislation and destroying the economy or by losing other revenue which will be expected to be replaced by the levy. This Bill is dogmatic and short sighted.

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).

A register of Businesses providing accommodation will ensure a level playing field for Hospitality businesses. The register needs to be cheap and simple to use and comprehensive in its scope. If all providers need to register, that is all that is needed. They can file their information on-line to be accessed by all relevant, government agencies. There is no need for a Licensing Authority. Anyone found to be trading without registration could be sanctioned without the cost of Licensing being imposed on other Providers and Local Authorities.

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).