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 Robert Griffith Roberts | Evidence from Robert Griffith Roberts
(We would be grateful if you could keep your answer to around 500 words).
The objectives seem laudable
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).
1) Main barrier is the justification in charging a levy on minors, which could very well be open to legal challenge on a number of grounds.
Even the Poll Tax was an adult only charge.
2) Presumably the levy will only be payable on "stay" and not on booking.
(We would be grateful if you could keep your answer to around 500 words).
1) Could disadvantage Parks close to the English border.
2) In its present form it would discriminate against larger families.
3) It does add to administrative burden of administering the levy and could mean rewrites of computer software.
(We would be grateful if you could keep your answer to around 500 words).
My understanding is that the worse-case scenario is 390 FTE job losses across the sector.
How does this translate into cost and has a cost/ benefit analysis of the bill's implementation been published?
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 balance between information contained on the face of a Bill and subordinate legislation is surely of a technical nature and should be left for people experienced in these matters to decide.
The Bill should be concerned with principles, amounts charged, and methods of collecting the levy e.g. would it be collected quarterly in the same manner as VAT (for those registered), and would there be group registration with one return & payment for multiple unit establishments.
(We would be grateful if you could keep your answer to around 500 words).
1. Children should not be taxed.
2. The Vat situation on the levy should have been established beforehand - you simply cannot have some accommodation providers charging vat on the levy and others not.
3. The levy should either be applied to every visitor accommodation in Wales or not at all. There should be uniformity.
4. The levy should apply to overnight motorhome accommodation (aires) operated by local authoroties and temporary campsites under permitted development rights i.e. there should be no exceptions and opt-outs, and all accommodation providers should be licensed.
5. Caravan Parks already have site licenses and theses licenses should incorporate the registration requirements of the Act - with no additional administrative requirements.
(We would be grateful if you could keep your answer to around 500 words).
It is not clear what "special circumstances" referred to in Section 7D of the letter means. It is open to subjectivity and argument.
(We would be grateful if you could keep your answer to around 500 words).
Main issue is taxation of children and ensuring that the proposed legislation applies to every accommodation establishment uniformly across Wales.