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 Tai Hanesyddol Cymru | Evidence from Historic Houses Wales
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Historic Houses Wales believed that the purpose of a register was to level the playing field between professional commercial operators and occasional or temporary participants who may need to ‘up their game’ in order to continue to compete in the accommodation sectors of the visitor economy. That would mean focusing on those trading without a registration number, off-register rather than chasing people for tax/levy.
The proposal in the Bill merely seeks to build a register for the WRA to collect a ‘bed tax’ from the usual diligent members of the industry. The scope of the scheme proposed in the draft bill is very disappointing: it merely provides a list of businesses who can be taxed, this is not in the spirit of the registration scheme consultation that we and our colleagues have previously engaged with.
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.
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It will be difficult for Local Authorities to identify occasional or temporary participants. Once again it will be law abiding Visitor Accommodation providers that actually pay the levy.
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The Welsh Government's own survey found that "great value for money is the number one influence in choosing a holiday or short break in the UK", so penalising visitors with a tourism tax appears to go against their own evidence.
As regards the Tourism Levy, Wales is not a region that suffers from over-tourism (aside from peak summer season at so called ‘honey pots’ around the country). Wales suffers from under-tourism. This proposed legislation will potentially make Wales less competitive and merely promote the rhetoric, that exists in some quarters, that ‘Wales doesn't want visitors’. It effectively undermines a great deal of the many millions of pounds spent in previous years promoting Wales to the rest of the UK and internationally both by the private and public sectors.
As the decision to impose the tax is devolved, will councils who make this decision believe that the Welsh Government will continue to pay their Local Government Settlement that they get from the enhanced population grant in full? More visitors equal more revenue.
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The Welsh Government’s economic impact assessment states ‘wider factors will influence both visitor and employer behaviour including the macro-economic context, therefore delineating any precise economic impact of a visitor levy would be unfeasible. Factors such as the weather, the time of year, levels of disposable income, what other destinations are doing, the state of the economy and other factors will all impact on visitor behaviour’. This suggests that it is not possible for the EIA to provide a impact assessment on Tourism Tax, which nulls the EIA.
Plus all of the other factors listed above in the EIA are currently having a detrimental impact on the tourism industry. The Welsh Governments Tourism Barometer: Summer wave 2024 states - 46% of businesses have had about the same level of business at best and 38% have had fewer visitors. ‘The most commonly cited reason for having fewer visitors is ‘weather’ (55% of respondents)’. This is followed by ‘people lacking in disposable income’ (42%). To introduce a new tax on top of the already negative climate based on these factors alone, let alone the impact of the 182 Day rule for Self-catering businesses alongside the highest level of VAT in Europe seems fiscally irresponsible and appeals merely to the populist vote.
Wales does not suffer from over tourism outside a few localised areas at peak season. Why is Welsh Government so keen to introduce a tax that will raise so little at the risk of potentially causing so much more long term damage to the Welsh Tourism economy?
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).
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We suspect that there will be enough legislative measures in place. A question for the 22 Welsh Local Authorities to answer.
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We believe this is the wrong time for this legislation to be introduced. It should only be introduced when the Welsh Government can prove that Wales suffers from over-tourism as is being suggested to the Welsh public.
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Charging for infants and babies seems extremely punative, especially for families on a low income.
A great deal more caution should be exercised in imposing any further tax burden on a sector which is already disproportionately taxed in relation to its competitors. It is a tax burden, which is already limiting growth and employment prospects. The accommodation tax in other European countries operates in a much less ‘punitive’ tax environment. UK VAT rates are more than double most of our competitors.
This will of course also disproportionately tax overnight staying visitors who make up around 10% of visitors to Wales. Day visitors will not be subject to this tax. Overnight visitors are the type of tourists that Wales wants to attract more of, as they spend, on average, twice as much as day visitors according to VisitBritain’s research. Introducing a levy on those staying overnight will actively discourage the visitors who bring the most benefits and contribute the most to Wales’ economy.