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 yr Iaith | Evidence from Cymdeithas yr Iaith (Welsh only)
(We would be grateful if you could keep your answer to around 500 words).
We welcome the principle of maintaining a visitor accommodation register, which will be important to the process of imposing an Article 4 order and producing better local development plans.
We also welcome the principle of imposing a levy on holiday accommodation.
This is an important opportunity to be able to create income for the community. Tourism is an important industry but it is currently extractive, and visitors use local resources and services so it’s not unreasonable to expect tourists to contribute to those services. In the long term, we would like to see a better, sustainable tourism model, where communities get much more benefit, but the levy is a step towards that.
The communities where tourism is greatest tend to be communities with a lack of community facilities and public services, low and unreliable wages, weak infrastructure and where affordable housing for those on local wages is scarce.
We would like to see the benefits of the levy being spent on alleviating the unaffordability of accommodation for local people and maintaining/providing community resources (which will of course benefit local people and visitors). Visitors are keen to visit thriving communities rather than dead ones.
We would like to reemphasise our ideas about expenditure by saying that it isn’t fair to quantify the entire cost of establishing/maintaining a holiday accommodation register against the tourism levy (see question 4). The register facilitates many other things, as well as the levy, and the financial benefits that arise from it may be difficult to measure. The money from the levy should therefore go to the areas above.
Other areas in the countries of the United Kingdom are considering introducing a tax on tourism, so it is entirely appropriate that we in Wales do the same.
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).
Many local authorities have not exercised their powers in the case of the premium on second homes and empty homes and introduced an Article 4 order.
Specifically in the case of Article 4, a number of local authorities say that they see the legislation as being too complicated, that they feel that there isn’t enough support or clear guidance or guidelines from the Welsh Government, and that they lack the resources to do the work involved in the exercise of the powers.
In the case of the second home premium in particular, local authorities are finding it difficult to fight against organised campaigns by second home owners.
If the Welsh Government wants to achieve the levy by giving powers to local authorities that they could choose to use, it must be ensured that there is motivation, support, clear guidelines and resources to assist them so that as many local authorities as possible use them the new powers. Without that, the benefits of the Bill will be limited and it will not achieve its full potential.
(We would be grateful if you could keep your answer to around 500 words).
As it is local authorities decide to impose the levy, people could choose to go to an area of Wales that does not charge a levy, at the expense of another area that does do so. That could mean that there is renewed pressure in an area that isn’t used to high tourism.
Regardless of how likely that is, it underlines the importance of encouraging local authorities to use the powers to raise a levy, for fairness to all areas.
(We would be grateful if you could keep your answer to around 500 words).
We feel that the assessment of the financial impacts is very pessimistic and perhaps somewhat misleading. It confuses the cost of administering the visitor levy with the cost of maintaining a holiday accommodation register.
The register is not necessarily something designed to generate revenue, but a system which, in addition to facilitating the administration of the tourism levy:
- ensures a good standard of accommodation for visitors
- ensures the safety of visitors
- assists councils with their local development plans by allowing them to measure the number of holiday accommodations in any given area
- assists councils to impose Article 4 in accordance with their new powers
- ensures fairness for tourism businesses by facilitating the process of compelling all holiday accommodations to meet the same standards and regulations as hotels and AirBnBs
- ensures that unknown holiday accommodations have to pay the business rates that are due
- maybe ensures that second homes registered as businesses as a way of avoiding the tax premium on second homes pay the council tax due.
Furthermore, we believe that it is unfair to measure the whole cost of creating the register against the income that comes from the visitor levy, because the register will facilitate the work of authorities and governments in many other areas. We also believe that creating the register itself can ensure higher income in some cases.
In other countries it is recognised that the levy raises net income. We do not see why Wales would be different in that regard.
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).
(We would be grateful if you could keep your answer to around 500 words).
We believe that it is important that members of the public and local communities are able to search through the visitor accommodation register to see if an accommodation provider is registered. In that regard, the register should be available for viewing and inspection. One possibility for that would be a searchable map, showing all registered properties.
There is no procedure for reporting unregistered holiday accommodation. There needs to be a way for people to complain to the Welsh Revenue Authority if they think that someone is operating unregistered holiday accommodation and a procedure to deal with that complaint.
(We would be grateful if you could keep your answer to around 500 words).
The proposed penalties for failing to comply with the rules seem very low compared to the income that owners can generate from their accommodation.
We are therefore concerned that it would not make financial sense for some providers to register their accommodation if they anticipate that registration would put them at a financial disadvantage in any way (including making them visible to HMRC).
We are concerned that this may undermine the integrity and effectiveness of the register.
(We would be grateful if you could keep your answer to around 500 words).
As stated in the Impact Assessment in the Bill's Explanatory Memorandum, the Tourism Barometer for summer 2023 has concluded that bad weather and the fact that people have less income to spend are the two main reasons that tourism businesses in Wales received less business in 2023.
Although less income to spend means that people will be more careful with their money, staying in UK countries will be cheaper than traveling abroad so a visitor levy should not affect tourism.
A tax or levy on tourism is already in place in most European countries, including Germany, Austria, Bulgaria, Catalonia, Croatia, Italy, France, Belgium, Greece, the Czech Republic, Netherlands, Lithuania, Portugal, Romania, Russia, Spain, Slovenia, Slovakia, Switzerland, and Ukraine. They have been in operation for a decade and more in many countries.
Tourism taxes have been introduced in less popular areas, for example in Lithuania a tax of €1 per night per person has been introduced in two tourist areas specifically in order to fund infrastructure projects and promote tourism.
There is no clear evidence that people choose not to go to these areas. Wales has a strong tourism industry so there is no reason to believe that a levy would significantly affect that.
In addition, the Scottish Parliament has passed the Visitor Levy (Scotland) Act 2024, which allows local authorities to set their own levy rates. Edinburgh plans to raise a levy of 5% on rooms from July 2026, and other UK cities such as Bath, Liverpool, Birmingham and London are considering a similar levy.
These cities and areas have enough confidence in themselves to raise a levy for the benefit of the area, and Welsh local authorities should be equally confident.