Impact on accommodation providers

Impact on accommodation providers

The Bill says that accommodation providers (known as 'liable persons') will need to keep a record of the amount received from a visitor levy. They will need to provide a return to the local authority every quarter that details the amount the provider calculates they owe to the local authority. If the accommodation provider fails to provide a return, this can lead to penalties. There's also a penalty if someone doesn't pay the visitor levy within 14 days after being reminded by the local authority. The longer they wait to pay, the higher the penalty becomes. If someone gives false information on purpose, or by mistake and doesn't correct it when they realise an error was made, there can be a penalty. If they hide or destroy a document that they were asked to provide, that can also lead to a penalty. The Bill also says that interest can be added to the penalties, which means the amount they have to pay will increase over time. If you agree with this proposal, rate it up (👍), if you disagree, rate it down (👎). Please tell us why you agree or disagree using the comment boxes below.


The north east of Scotland - Aberdeenshire - strongly relies on the tourism industry and wider tourism sector. I believe that should a visitor tax come into effect it would dramatically impact on tourism in Aberdeenshire.

Yes the provider should have a responsibility to collect this, as they are the ones benefitting from letting their accommodation. The rules should be tight so that there is no ‘wriggle’ room.

why should a small self catering business have all the extra work of administering this levy, as a very small business we do not have accounts staff to carry this out, as with all government processes there are always penalties/ charges. We would have to charge a percentage on top of the levy to cover the cost of the book keeper to administer these fees which will in turn increase the cost of the levy. self catering is already on its knees with the STL legislation and the drop in income during Covid, many of these businesses are just making a tiny profit, this will make it unworkable and pointless and increase the cost of holidays within Scotland. if the Scottish government stopped wasting tax payer money they would have the money to upgrade the infrastructure that is needed in Scotland. i am certainly not going to act as a tax collector for the government, we are too busy working 100 hours per week already!!!

If the aim of this bill is to reduce visitor numbers because certain parts of Scotland cannot cope with visitor numbers, then this is certainly the way to go. However I think such a tax is gross unfair. Cruise ship visitors would not pay anything.

Similar schemes are heavily used across Europe and don’t stop visitors holidaying in destinations where charges are applied. Why should Scotland be different?

The results of the pandemic. Inflation driving up all operating costs. New licensing legislation (not easy to satisfy the raft of costly boxes to tick). Thin margins. Consumers watching their pennies. What a stupid time to add another time and cost burden on micro businesses. Do you want people to viscerally dislike you?

it's really not difficult -owners are already obliged to keep records for tax, for safety reasons and such like. Again, it all seems to work in Europe and has done for years - if it all seems too difficult, we could sek advice re how to deal with any pitfalls. We all tend to complain about new things before they are put in place - maybe we need to accept that sometimes, if we just get on with what we are asked to do, there's not really a problem other than our reluctance to change.

Payment terms of 14 days and fines for non payment with interest to businesses for the collection of a government tax seems very heavy handed, and shifts the burden of the state to private businesses. Yes they could have to collect, however, the approach feels anti business rather than supporting those who create employment and economic activity in our cities

This mechanism for charging can be relatively simple. It might be a percentage charge of accommodation revenues, or a fixed charge per person per night, but both of these will be simple to record and administer. The system of recording and payment could be similar to that used for VAT. To charge a percentage of accommodation revenue rather than a flat rate per capita would, in my opinion, be the more equitable, in that this would mitigate the relative impact on lower cost accommodation.

I live in the Highlands. The only people in favour of high visitor numbers are accommodation providers, many of whom don’t even live in the area or have any connection to it. There should be strict rules round the collection of the tax from these people, many of whom make a packet out of this business and it shouldn’t be a problem to do this.

I run a small hotel and I am completely opposed to placing the burden of collecting this tax on accommodation providers. This will add hours of extra work to our accounting and cash reconciliation processes at a time when many businesses are struggling to find staff, to say nothing of the increased wage expenses. In addition to this expense, every single visitor levy payment that we collect will also incur bank or card payment charges. There will also be extra work, and much room for error, at check in. Frequently, people book rooms for two people, and then one person cannot travel. They seldom update us on these changes, so there is much scope for people being charge a levy for two, and then having to be refunded - yet more work and administration. Many accommodation providers are on their knees after the Covid lockdowns, and current spiralling energy, supply and staff costs. There is no good time to saddle small businesses with yet more to juggle - at their expense - but this could not be a worse time.

The council will have to take on more staff to manage the scheme and the compliance.

Make it as easy as possible. Too much red tape and overly convoluted processes for most when it comes to government and local authority affairs. Listen to businesses who know how to run things best.

You really need to have joined up thinking here, the tourist industry in Scotland provides a healthy revenue stream and jobs. The accommodation sector has already had the extra expenses and burden of applying for the Short term let licence which has already removed many self catering properties available especially in areas with high footfall over the last couple of years, at a time recovering from the covid restrictions. This extra proposed levy on tourism in Scotland is a death nail on the industry not to mention the added administration for accommodation owners to collect and pass this tax on to the Government. How is this helping the low cost Housing shortage?

More bureaucracy and administration for businesses to deal with along with the burdens of other legislative and compliance requirements which just go on. This "initiative" adds cost to businesses, removes another portion of tourism income into government coffers and reduces investment in businesses and wages. Helping more businesses into administration instead of supporting business growth.

This is a huge burden on small business and would be akin to another VAT bill, especially if it is a complex percentage calculation based on a proportion of the overnight costs ( i.e. excluding cleaning costs etc) Most SMEs need an accountant for their VAT bill - at some cost. Many SME owners may want someone to check over their calculations in fear of making an error that would incur penalties. This will place additional costs on them at a time when they are already forking out for a poorly thought through Short Term Let License Scheme etc etc. Can it please be kept simpler, like a flat fee per night per room, and submitted annually! Easier to calculate, less need to be double checked, less likelihood of mistakes and penalties for the poor accommodation providers, and less burdensome reporting. Less work for the local authorities too! Most small businesses don't have accounts department to do this calculation - they have one or two people doing all the jobs from bookings, maintenance, cleaning, pay bills etc. Once again it shows a complete lack of understanding by Scottish Government of the nature of such small businesses.

yes this is fair, if you financially benefit from tourism, play your part. it works really well elsewhere in europe, add the levy to the bill on all accommodation and that is paid to the council

I tentatively agree but feel as though accommodation providers should be rewarded upon uptake of this legislation due to the potential long-term benefits of the bill. Surely this can work for everyone

This is Government version of organised crime and tax is protection money. Sign up to the scheme we created, do all the administrative work and if you get it wrong we fine you even more money and potentially even prosecute you. This is grossly unfair and no right thinking business should sign up for this

KGC. As a micro single accommodation provider I am against the way the TL will be applied. I am aware that other countries already have a version of tourism tax, which if applied fairly and reasonably is perhaps a good way to fund the infrastructure needed to support this industry. The current proposal is expensive and unfairly directed at only a portion of the tourism industry which is not right. Why not use the Norwegian approach and use a "road toll" number plate recognition system to apply an appropriate charge. I live on the NC500 route and I feel it would be very unfair for bricks and mortar accommodation to be the only source of TL. A vast number of campervans, campers and cars use this route, and have an impact, and would pay nothing! Local businesses and residents could be excluded through a number plate registration scheme. Also the burden of reporting quarterly in a busy season, and rapid penalty periods is unfair. Why not deal with it an the annual tax return stage, when double counting mistakes can be avoided? This would be less onerous, and onerous it will be in its present form!

It will help regulate market

It should be on the visitors who are not using bed and breakfasts or campsites

the levy should be on users that are not using formal accomodation.

The Europe example misses out that our VAT is higher already.

Another onerous responsibility placed on to accommodation providers. This will just increase day trippers, which arguably have most impact on the environment!

After 2 years of lockdown most businesses are already struggling to survive and this will just add yet another burden.

Recording number of visitors isn't huge extra burden. Many places across Europe manage it

There should be an easier way to collect levy; eg direct payment to a central account which could be done by the visitor at the accommodation they are booking into instead of the provider having to administer; or direct transfer from the provider to a central account. The software must exist!

So really you want to apply the tax but you want accom providers to supply the manpower and resource to administer it. This is an extra burden on businesses already struggling coming out of the pandemic or have you failed to notice the boarded up businesses across Scotland! As usual an ill thought out proposal from Scotgove along with the SLT, DRR, LEZ and HMPA. Scotland is now competing with the, much cheaper, rest of the world including new destinations! In the winter time many accom providers have a workforce staying in them who help rebuild Scotland's already crumbling infrastructure - Calmac! Roads, Electrics, Wind farms etc. Are they expected to pay the TAX are much needed winter tourists expected to pay the TAX! Where does the money for the extra policing of this come from????

this sounds like we are going to be doing the work of the governments and councils...and they can penalise us for not doing their work for them! Most people in rural areas are having to do more than one job already just to live here, and now to add this is just killing the small opportunity to make a living in an already difficult area to do this

Liable persons should be recording visitors/visitor nights to ensure all taxes due are paid and this would provide an additional audit tool for those submitting tax returns. The data generated could be used to show patterns of tourist numbers during different times of the year and inform policies and improvements that support footfall.

Accomodation providers in areas not heavily saturated with tourism (most of rural Scotland) are already struggling with raising living costs: more costs to run accommodation and less customers able to spend money. This unfair and unthought bill will only add more costs and less visitors, causing a drastic reduction in accommodation providers and therefore affecting rural economy and Scotland's economy in general

Providing a return quarterly would be overly onerous businesses and surely on local authorities to administer too. It would be more efficient to do annually then more of the revenue would be used for public services than administrative costs.

Tax should always be collected by the government in some shape or form. In the business I work in, the Council previously invoiced for rates directly to the second home owner, then they changed it to our business collecting on their behalf and then it was decided that as somebody else was now collecting it that service should also pay vat. Increasing the end cost to our customers, 95% of whom are Scottish. We already collect tax for the Council already. This would be in addition. The admin costs for both business and Council in checking a return is a burden both can do without.

This is another level of bureaucracy that will need additional staffing within council. In cities it will probably generate money but in less populated council areas it will be a burden, which may lead to higher charges to compensate.

Businesses do not operate to generate administration for their business as it costs money which could be used in many other ways. Businesses are already paying increasing business tax, increasing rates and increasing operating costs. I strongly disagree that the accommodation provider becomes a tax collector and be held liable for it the local authority. This panel needs to understand every tourism business commitment to the Scottish economy just by operating and not penalise these Scottish businesses. In addition why are cruise line businesses excluded from this levy? Cities in Europe are addressing that but again Scotland is looking in the wrong direct. Support tourism businesses not penalise them.

This will add a further burden for accommodation providers who are already facing an increase in bureaucracy and regulatory requirements as a result of the STL legislation.

It may be tricky for smaller providers to comply.

It is an added burden, however a spreadsheet should help with keeping track of the amount received/owed to the local authority and keeping a tally is not an onerous task.

STL is already set to turn legitimate small business owners into criminals- so much for SG working with business. So much for encouraging community owned and led visitor attractions - volunteers are already like gold dust for these important projects. This will stop community tourism in its tracks. In my opinion the only body that should have access to my books is my accountant - certainly not some jobs worthy in the council. Scotland is fast becoming the worse place to operate a small business. No understanding of the cost of doing business as a sole trader or micro business. It’s very sad to see entrepreneurial spirits being crushed and folk giving up and leaving the industry exhausted by red tape and lack of empathy from those in power.

We haven’t yet seen the impact of STL licensing which is a huge bureaucratic burden on a sector that has a large proportion of very small individuals who will be overwhelmed by the additional burden. The implementation of STL licensing has been muddled, poorly planned, under prepared and resourced and disproportionate to many small providers. We do not need another layer of legislation and red tape - we need understanding and support for small businesses and a key - and now struggling - sector of the Scottish economy.

I disagree with this because accommodation providers have already been hit with increased costs - introduction of STL, increased electric & insulation costs, increased administration costs. In Orkney we only have tourists around 5-6 months of the year unlike the central belt and other cities. We still have to heat accommodation for other 6 months to stop dampness. We have visiting workers who sometimes also stay in winter who surely should not be taxed, also all Orkney residence at some point have to go to hospital at some point of mainland and should not be taxed for staying in accommodation South for non tourism related visit.

I write as Chair of the John O Groats Mill Trust, a small community trust focused on improving the lives, opportunities and welfare of our local folk. The Trust plans to use its old watermill as a heritage and drop in focal point for local folk and as an important tourism "must see". By doing so the Mill will play its role in boosting the local economy. It is difficult to argue against the ambitions of those calling for a tourist tax. The Devil as they say will be in the detail. In our case, the mill itself will be run in conjunction with two self catering units adjacent to the mill. Any income generated by the units safeguards the Trust and ensures its sustainability in maintaining the historic Mill which like many other historic buildings will never draw in huge amounts of revenue. The Trust is run by volunteers. At the moment it is working through the nightmare process of providing Highland Council with all the information deemed essential in its application process for licensing of accommodation providers. Sledge hammers and nuts spring to mind and one is left wondering why all this information is required. Do not misunderstand. The Trust has no fundamental objections to a licensing system. But the impression is that those asking for this information have little concept of the time and cost in gathering it. Ignoring the license fees for the two units, an estimate of the costs so far is well into four figures, a substantial dent in the money the units raise, all of which goes back into the fundamental aims of the Trust. This ignores the many voluntary hours spent, which if paid for, would raise costs enormously. Perhaps you might from the above begin to understand the Trust's concerns about yet another burden being placed on it and its volunteers. This has the capacity to be a huge can of worms for a voluntary organisation. The Trust, it seems, along with many other small businesses are to be the tax collectors for the Council. Its easy to see that the system could be open to abuse and under-reporting. So this raises the spectre of a hugely bureaucratic recording system. This may well be ok for large businesses able to set up and maintain computerised records. But what about the Trust and others at the opposite end of the scale? The time involved in gathering this information is frightening. The intrusive nature of the information which may well be asked is equally problematic.  We have little faith that the people charged with establishing this tax collection system will have any concept of what it might mean for those like us at the sharp end.   An interesting point is that in any system such as that envisaged, the Council, like any other organisation will factor in the cost to itself of operating the system. So not all revenue gathered will then be available to further the aims of the tax. Will any similar consideration be taken into account of the cost to those who will be burdened with gathering it? I look forward to having the Trust's concerns allayed. Sent from my Galaxy

It's a good idea to do it like this.

I am a host and an accommodation provider. I can also be a tax collector if you so wish. Like everything else this government brings in it will be over complicated and no dount unfit for purpose. This goverment is incompetent. Don't take my word for it... even Sturgeon says Baby Boxes was her crowning achivevment. That'll probably top anything the current FM does. I am not a fan.

Aside from the actual charge the whole administration burden is on the operators often small business. Who will pay the cost of that? Again will just increase cost to tourists. The idea as well that every council has its own system will make it even worse as any software solution will have to know which locality you are in. For as wellsome this may mean multiple systems and returns.

This is too burdensome for many people who operate short-term lets as a bit of extra income in retirement or to top up minimum wages in remote rural communities. It is akin to quarterly GST returns but for essentially non-commercial entities. There appears to be an over emphasis on penalties and if as much thought that has gone into penalty structure was given to other areas of the suggested scheme then the government might have come up with something that was more appropriate and seen by the country as workable.

if a local authority does not engage with third party providers, then the requirement to hold records on visitors would seem to mean that accommodation providers would become data controllers and be subject to those responsibilities and corresponding liabilities. This would seem to be disproportionally onerous for small businesses. For example, I rent a room out via AirBnB. They process payments and booking details for me, so I do not hold/process any guests' personal information. That would change as part of this if they did not have an agreement with my local authority (Edinburgh, who are evidently quite averse to AirBnB). Regardless of this, the requirement to hold data on people with exemptions/their exemption vouchers (section 10) may mean the requirement to be a data controller if that falls outside of the third party agent's payment/returns agreement with the local authority.

Complex calculation required for each stay, including handling exemptions + keeping records. Payment timetable out of synch with other accounting requirements such as VAT resulting in additional bookkeeping sessions each month all resulting in additional costs and complexity for the accommodation providers. Not only is all this extra work and management expected for no payment, the draconian penalty system proposed is completely sickening.... "We expect you to do all this new work for nothing and if you don't, or make a mistake you will be punished" - doesn't seem right, does it?

How do you make every BB, Hotel, Guest House and selfcatering pay if you don't have a register of all the operators in Scotland. The councils now have a list of the operators that have either a short term letting licence or a liquor licence, because they follow the law. There are 1000s of properties out there that operate under the wire, they aren't graded by Visitscotland or the AA. Don't use the big OTAs like or AirBnB. they will continue to operate without paying a levy as the council doesn't have the resources to investigate all the potential operators.

This is an extra administrative burdon on accommodation providers who are already operating under increased overhead costs. Accoomodation providers will be faced with the expense of updating comuper systems and incurring credit card commission expense on payment of the Tourist tax.

It's another tax from an easy source. The reality is accommodation providers will be paying it. We already pay 20% agent fees, tax, council tax, vat, and live on these communities we are discussing. Our guests spend millions in local businesses and support economies across the country. Easy target for stretched council budgets. They need to address the overspend and expense accounts of these councils. Not make me a backstreet tax collector.

4 people DISAGREE Concern that the local authority has not got a handle on its own landlord system. How will they manage this. (This is a reference to PSL in Edinburgh. Private Sector Lets). Does the council have the ability to manage this? Some people (accommodation providers) will find it hard to manage the process. For example older people who are not digital. There should be some incentives for accommodation providers (rather than penalties). What are the benefits for them?

Another disastrous idea by the Scottish Government. The levy if it goes a head should be a full UK not Scotland. It should be collected at airports and ferry terminals from overseas visitors as they enter or a departure tax (a UK conservation tax) If its collected that way everyone pays, whether they are in campervans, tents hotels etc. Accommodation providers have enough to do running their own business. British resident’s should be exempt. Short Term Letting License is a fine example of their incompetence. 32 council’s operating and they are all setting their own requirements and exemptions!!!! Business rates should cover these costs not being filtered away from the area. Collect in the area invest in the area. The levy if introduced must be the same for all areas. Ideas are easy, implementing them and not consulting the people in the industry is unacceptable. It very much feels like “we will listen but ignore” Everyone uses cards so if you collect the levy you have a card percentage to pay. For every £1000 levy you collect you have a 3% cc fee £30 who takes that hit. It shouldn’t count as part of your business turnover. The DRS scheme is another fine example. For it to work it has to be a UK not stand alone Scotland.

Cannot see how else it can be implemented

Accommodation and service providers already pay business rates to support local infrastructure. Their businesses are scaled for the number of visitors and tourists that they attract and therefore the local autthirities already benefit from the value of tourits or vistors to their local economy. They should look more closely at the ratable values of businesses within their area rather than set up a new levy with all the bureaucracy and admministration that entails. Corporation and income taxes from the success of these businesses is also channelled towards these authroities so the local authorities need to make a better case to central and district government.

Extra admin burden for small accommodation providers. As a single handed B&B owner I already have a huge amount of work to do without an additional administrative duty. Who pays the card provider fees for collection of the payment, who pays for our time in collating the figures. I already earn significantly under NMW as self employed. Now you want me to do more for you for free??

This will increase our administrative burden greatly. How do we account for workers, how will we apply a % levy after customer discounts, will it affect our VAT? The 14 day window is too short. Can I issue a fine for each day our roads are not fixed or broadband is not deployed to my area?

This is completely onerous to expect small business owners of self catering accommodation to have the know how or time to collect and police the collection of this tax. Self catering holiday accommodation is already subject to more red tape than any other country. This is one more nail in the self catering industry. I do not understand why the Scottish Government are trying to decimate this valuable sector which provides high quality accommodation to international tourists who spend a great deal of money in the local economy during their stay and the tourists will be put off booking by the bureaucracy.

Another administrative burden - forced upon us with penalties if not processed on time. Let the STL settle down first before more daft proposals are put into law when the majority oppose them.

In parts of Europe tourist tax is a small part of holiday expense and the accommodation providers seem to accept this role. I would never be put off staying in a resort because of a small charge, and I don't expect visitors to Scotland will be either.

These threats are enough to ensure that those who have not given up providing self catering already, will certainly do so in the future. What right to we have to charge a tourist tax to a local family coming on a self catering week on a farm to get away from it all and celebrate granny's birthday. They stay on the farm for a week, don't go out, don't visit the local cities - but pay a premium for every child and grandchild to come away for a quiet family celebration - Nuts!

I have no issues with the reporting of numbers, but quarterly and so heavy handed with the fines - nah

It is not equitable or proportionate to make tourist operators become unpaid tax collectors. It increases the cost of running businesses with no return to the operator. There is too much red tape to deal with already before adding in the prospect of a disorderly and onerous extra council run tax.

I am part of a hillwalking club that owns 2 properties. These are let out to members at minimum cost and are purely for hillwakers. Club Members Volunteers to maintain and run the bookings and this would add an extra burden to manage the paperwork etc. This adds a burden to volunteers who are not being paid. The club charge for the property is minimum to cover costs of maintinaining the properties. Any additional income is put into club funds to help with subsidising transport for hill walking day meets and donations to restore hillwalking paths etc Properties like this I feel should be excempt from the bill.

Not a significant burden

To much work involved, include in the annual tax assessment as a line item against income received from visitors.

It is inconsistent with the idea that this is actually a visitor levy. This looks more like a levy on the accommodation provider. It also provides the local authority with confidential business information every business. A true visitor levy should be paid by the visitor and the visitor held liable to pay!

Disgusting. Are accommodation providers suspected criminals or valued partners in this? Again demonstrates this is straight forward income tax and has nothing to do with tourist development.

Puts the full onus on the provider

Another job for us to do for the highland council? Paying MORE money to the god awful highland council who do nothing in return? Are you joking? There’s a reason the entire population of the highlands wants the council disbanded. You should be helping and supporting businesses to rebuild after the mishandling of the never ending lockdowns up here not heaping MORE tax on people. Words fail.

Yet more administration is being heaped on accommodation providers on top of the Short term licence recently introduced - and it's yet another example of the Big Brother Scottish state taking more control of its citizens' activities through regulation.

This will laborious and time consuming. Also may be easy to avoid paying tax to council. Don't think the council will have the resources to "police" every accommodation provider. I already provide an annual return to rates department, would be not be better to simply charge a flat fee based on turnover.

There has to be some way of identifying and recording additional income and the accommodation providers are the only people that can do this.

It’s even more work for accommodation providers. On top of recently having to apply for the other load of nonsense, the short term lets licence. A money making scheme for councils for sure. It’s just one load of bull after another. I’m minded to sell up and exit tourism

The proposals put in place seem reasonable, and it is better that this happens when everything is rolled out. A percentage rather than a flat rate would seem fairest

it must be the accommodation providers as they are at the front line. It needs to be simple to operate. It may be worth finding out how the SAAS valley in Switzerland operate theirs, as it is instantly recorded - because one of the benefits of the (summer) tourist tax is free travel on the ski lifts; so the lift operators know from your 'tourist card' whether you've paid your tax or not. Admittedly it's a small area. I disagree with the punitive nature of this part of the proposals.

It puts the full onus on the provider

Having already paid for the stl icence this is another tax and hassle and stress. Tourists already pay ALOT to come to Scotland. Don't make it more expensive for them and us. In no way is this a benefit for us who provide accommodation.

I disagree with adding interest to pentalties. How are local authorities actually going to be able to afford to carry out this chasing and checking??

We are still recovering from the impact of COVID-1, having to cope with ever increasing interest rates, energy costs, food prices etc. with the majority of public & businesses struggling. This levy will have a significant impingement on tourism and will lead to a decline in numbers staying & visiting. It will also effect those who already pay out to be licensed. Surely if a levy imposed & visitors do not pay will we see another increase of to those involved in the hospitality sector. I can envisage a huge increase in wild camping, caravaning & motorhomes parking/setting up to avoid paying levy. This will not be beneficial to the tourism trade or the environment but cause a detrimental effect to the environment. I for one do not support this levy, it will kill tourism and people are already struggling with the standard of living today.

it would be another burden on visitors and accommodation providers. We've already had Covid, Brexit and the new STL.

I agree that this will be an additional burden for both business owners and the local authorities, but the quantum of work involved does seem small given the benefit of the sums of money on offer. Perhaps relief can be given to smaller accommodation providers to only have to submit annual returns, for instance. Or perhaps a nominal fee can be retained by the accommodation providers to cover the costs of the additional administration required?

Yet another money collection burden. What does the liable person get out of it?

In my view this is a false threat as the criminal justice system is unable to cope currently with the remit it already has. Many areas of quasi civil/ criminal matters are not prosecuted, low level diversions take place to conceal the extent of non compliance.Penalty driven policies are a waste of time when there is no meaningful follow up.

Recording the number of guests is a relatively simple task that most businesses must surely already undertake. It is routinely done in several other European nations.

All accommodation providers should be keeping records of the ££ they take in so this shouldn't be much of a burden.

It imposes yet more bureaucracy on small businesses for no discernible benefit whatsoever.

As many others have said - it seems to work fine in many other parts of the world. However it needs to be as simple and easy to manage as possible to avoid additional work for small businesses and the money raised being swallowed up by adninistration costs

I assume that software will not be provided to manage this, so this is just another paperwork burden on small business owners already struggling with the STL licence. How can this be policed? The council nor the accommodation providers will have any way of absolutely proving the amount of accommodation that has been booked.

I've run a small hotel for 34 years, working over 80 hours a week for over 10 months in each of those years - nowadays mostly on marketing, administration and managing operations and staff. Now I might be faced with further administration and another tax - Does anyone really have the impression that smaller businesses will be able to pass this tax on to visitors when competition on rate is so high? Furthermore OTAs already take 20%, gross, VAT consumes another 20% of any night's tariff. Whoever came up with this "bonne idee" should perhaps speak to small letting business operators, bearing in mind the percentage of the whole that they represent. Hopefully sufficient numbers of small operators will be aware of this bill to engage in this consultation process. However, coming at a time of year when they are all exhausted serving the needs of their guests, I think that is unlikely. I'm sure this will pose little issue for larger concerns who will find it easier to pass on the cost in full to their visitors and have staff to administer the process. Who is speaking for small business in this matter, however?

It really does not address the real issues experienced in Scotland's rural areas, where dirty, casual (not genuine wild) camping and camper vans cause more impact. Focusing only on accommodation is perhaps a city solution but would fall short of taxing those visitors which cause most impact in small towns and rural areas - the campers, the cruise ship passengers and other day trippers.

I work in tourism as an accommodation provider and know how under-resourced both my business is and how under-resouced the local council is. Neither I nor they have capacity to deal with quarterly collection and reporting (and I would, it appears, be doing it unpaid!). I report to the tax man annually - surely tying the two together would make more sense? Will only result with those that struggled to stay afloat through covid, then were stabbed with the ridiculous hidden costs of the STL (ever tried getting an electrician to pop out and check things in the remote Highlands?) and now expected to become unpaid tax collectors leaving the industry. I'm not even opposed to this scheme, just think it needs a little time for the farcical implementation of the tourism licence to be fixed and a lot more consideration over who to collect from and when before you kill tourism

• General conversation that people felt the onus to gather a levy should not be on accommodation providers. Though one person did feel that if it was well run they would do but didn’t have confidence it would be. • Concern about the management of funds and the return of the money raised to communities. • Money should be ringfenced • What happens if a tourist doesn’t pay. Concern the onus falls on accommodation providers (penalties etc) • Big admin burden, Quarterly returns is a lot. • Financial burden on providers • Penalties are draconian • Charging a % rate creates a higher risk of getting it wrong (for the accommodation provider) • Makes the accommodation provider into a local tax collector • Are there other ways revenue could be raised?

A record has to be made somewhere and it is best at source

The impact will be substantial and negative • Expect this to happen • Burden on accommodation providers is already substantial. We have lost accommodation in this area because of bureaucracy. Tourism infrastructure is fragile. Far more accommodation available in the 1990’s – Impact of Short term lets legislation, shortage of staff (for accomodation providers) Many older and retired people provide accommodation – for this age group to learn new skills to deal with new regulations. Many have given up. • The levy does not capture visitors who don’t have such a positive impact on the local economy such as day trippers/overnight stays, vans? • Could other options be considered? What about a vignette – window sticker for a ‘paid tour’ an e- tag system as used in other countries • What about campervans • What about using the A roads and charging there • For many accommodation providers this is not their main income – will they be prepared to take on these new responsibilities (the group feeling that there will be more closure. Two in the group had already given up their accommodation provision due to the Short term Lets legislation and GDPR concerns • Knock on impact on other tourism service providers • Fragile local economy

Small providers can’t cope – and still challenges for larger providers – and could become a deterrent for new providers Short term licensing has already closed some business Council will need to employ extra people to manage Need more detail on what records you may need to keep Cost benefit analysis – manage the varied needs and infrastructure for small to large scale providers With ferries being unpredictable, people often help and put people up for the night (sometimes with no charge) Is there comparative data on where this works? Look at Iceland’s model Can we implement eg island solutions EG charge on the ferry – what are North Ayrshire’s views on this? How will it be policed EG ferry cancelled and therefore guests need to stay additional nights?

quartely is far to often - it should be an annual return

Another burden for businesses, who become unpaid tax collectors, with the threat of penalties. It is completely wrong for some tourists to be excluded, like wild campers, campervans and and cruise ships, all of which arguably make the most mess to the environment on land and sea and contribute little or nothing to the local economy.

Accommodation providers should not be tax collectors for Local Authorities. Local Authorities will subsume any levies and no one will benefit if such a levy were to be introduced anyway.

Accommodation providers have enough red tape to jump through just now thanks to the Scottish government, if the government decide to introduce this, then they themselves should be liable for taking the money, filling in all the forms that will be needed, and chasing those tourists who haven’t paid. Not the accommodation providers.

Accommodation providers are accommodation providers, not tax collectors. It's a hard enough job anyway, with eighteen-hour days, seven days the week the norm for many folk during the busy season. Though if the levy is big enough, they probably won't have too many customers in the first place

Why does the councils need more money and now again trying to penalise small businesses either starting up or just keeping their heads above water. 10 years ago we were always on the top 10 lists of places to visit, we aren't even on these lists anymore. I mean come on, "Lonely Planet’s 2022 Readers’ Choice Awards" featured Zimbabwe as country to visit, and instead of drumming up more ways to attract tourists as per your 2030 Strategy, what do we do - yes you try and impose a tax on visitors. Scotland is already expensive enough to holiday in, why do you want to add to the cost and then hold the accommodation provider liable for these costs if the tenant doesn't pay. Ask any sales person what the hardest part of their job is and they will tell you it is to retain customers. How many people come to Scotland year after year on holiday or do most only come once? I know most only come once if at all these days, so its not sustainable. Get the Council to sort out its current Budget first by sorting out its Public Procurement spend. This levy isn't going to sort out years of mismanagement and its only going to drive tourists further away.

I realise someone has to administer it, but those who do should be recompensed for the time and efforts (and I imagine quite considerable set up time), not just be threatened with penalties.

How is commission based tax collection going to work. On per guest, are you taking off my cleaning costs, credit card commission, my OTA's commission, are they paying the tax on the VAT, so a tax on a tax. Are you going to pay me to collect your tax.

This will put a very considerable burden on small providers.

When I purchase accommodation I generally have to give my address and if I’ve driven my car registration. Information is also given on booking. I’ve stayed in place where all the record keeping is manual which I imagine could be contained in a software update to current systems.

Small businesses have been struggling since the pandemic and with all the new legislation this is another nail in the coffin of small tourist accommodation providers. You are at risk of lowering the accommodation provided again as small ones will either just close or sell. Again an ill thought out piece of proposed legislation.

The still-to-be introduced short term lets licensing scheme is already adding a significant cost to providers. This means accommodation costs are rising to compensate for this. To introduce a VL will further add to this. It would be much more prudent to establish the STL scheme for a few years before adding this extra VL scheme.

Why does it have to be quarterly, we're busy enough as it is in the mad summer season, can we not have the flexibility to pay within a tax year - for some of us, its much more efficient to do with this at the time of our tax returns.

Accommodation providers tend to make a huge fuss about this part. The rest of Europe has proven doing these recordings is not much of an issue, it has been in place in plenty of places for well over 20 years.

As I am totally opposed to the levy why should I be forced to collect the money from our guests

There is far too much expected of people running a holiday home business already. These are very small businesses with very tight margins with property maintenance, utilities, cleaning, management fees already increasing. The Scottish Government seem to be doing everything they can to shut down these tourism businesses when they should in fact be encouraging small business. To expect holiday home owners to have the time to levy this tax is unduly onerous. The tourists by coming to Scotland already invest in the local economy by paying for goods and services without charging them additional and annoying fees. Tourists can vote with their feet and go elsewhere.

Surely there's enough admin burden on these people already? Stop deflecting costs away from general govt and onto local businesses. If there's funds to be raised do it through general taxation at Govt level to minimise costs and impacts.

We have just had licensing come in and now this... Highland will be ruined as it relies on the industry and this will kill it!!!

This is just an attack on local people trying to survive in rural areas. It seems designed to destroy our communities and our economy which is already too dependent on destructive over-tourism. B&Bs need supporting, not attacking.

I don't necessarily disagree with the idea of accommodation providers collecting the levy and passing it on to the government, although it should be made clear to tourists that this extra sum is not going to local businesses but to the government or local council. I do, however, disagree strongly with the visitor levy being charged ONLY to tourists staying in hotels/B&Bs/self-catering houses. Much of the negative impact of over-tourism comes from the hordes of visitors who come to my area (the Highlands) in motorhomes, campervans and other vehicles. These tourists clog the roads, often making life difficult for local residents during the tourist season, and many park and camp irresponsibly and cause damage to the natural environment by ignoring the Scottish Outdoor Access Code and/or disposing of their waste irresponsibly. Whether or not they stick to the rules, they need to pay the Visitor Levy and contribute to the provision of the infrastructure they use. there is even an argument for them paying a higher levy, because people in motorhomes tend to stock up on supplies in city supermarkets and put less into the local economy than those who are paying for accommodation provided by local businesses.

Difficult to give a straight agree/disagree answer. I'm an accommodation provider and wouldn't find the bureaucracy a particular burden. So I'm saying I agree. However, I would STRONGLY DISAGREE if camper vans do not also pay a visitor levy. Accommodation providers in the Highlands have gone through SLT licencing and none of it addressed the problems of living on the NC500. If this further impacts Highland accommodation providers without mitigating the effects of camper vans and the NC500 (which we never asked for) the industry in the Highlands will feel very aggrieved. There are only five major roads into the Highlands, there is no reason ANPR cameras can't be used to track visitor vehicles and enforce any levy.

Why should the onus of paying be given to the accommodation provider

This bill just adds to the ever increasing rules and regulations that holiday accommodation providers are obliged to adhere to just as they are wrestling with the financial and extra administration burden of the short term letting licence. Why should they be liable for collecting a tax for the councils - and free of charge?

Cost - one report suggests it will cost a small business up to £500 set up the system to collect the tax and up to £850 a year to run it. There is no indication as to the cost to councils for set up, collection and policing nor how much money is expected to be raised. Any business would have a fair idea of these costs before asking stakeholders to give an opinion.

It is unfair that accommodation providers, many of whom are sole traders, have already been burdened with the paperwork and expense required to obtain their short term let licence and now you intend for them to have more bureaucracy imposed on them.

Accommodation providers should receive a fee from the local authority to provide this service. There is significant paperwork and systems changes required in order to reliably record these transactions and keep appropriate records.

As a small provider, these additional time and financial burdens are more onerous than for larger hotels etc who have admin staff and automated systems. This would be an additional workload for us and cost without providing any net benefit. Surely we should be concentrating our efforts on getting to net zero? If the tax was to be raised for that initiative I would not have a problem.

Quarterly is too frequent

Small business are busy enough. Their income already contributes to the community.

As a Scottish person it is already too expensive to holiday/travel around Scotland. This will only make it even more difficult. I want to be able to see my country, not to have watch as only rich people can afford holidays in Scotland.

Should be part of any business to record this surely.

Fair enough, but if climbing club huts are in scope, this will be an onerous burden for a role filled by a volunteer.

Why should I administer and collect a tax on behalf of the council for free.

Needed as an incentive for accommodation providers to comply. So long as it is properly organised it should not be too onerous

A huge impact on accomodation providers on top of all the work involved in the STL Licence application. An additional unpaid job collecting tax for local councils with a fine if you don't. Plus they can inspect your premises, why?

This adds an extra burden to businesses struggling to stay afloat. Our country has dwindling services. Those still open are struggling on a knife-edge to survive. We need thriving businesses for a thriving Scotland.

This makes overnight accommodation providers suddenly become unpaid tax collectors for the local authority ('liable persons') simpy because its the easiest way to raise money, it iis fundamentally flawed as it doesnt target the visitors who use local facilities e.g. the cruise liner passengers who have been excluded from this BIll altogether for the ridiculous reason that it would have delayed the process. It would be unfair to introduce it at all as currently described and should not be imposed on accommodation providers at a time that all are struggling to cope with the cost of living crisis and the huge administrative and cost burden of complying with the short term let licencing legislation.

Basic economics here. The tax is going in reality paid for by the accommodation provider. It's a cost to the business. The price of the room goes up and some people will not stay in Scotland and the business loses sales; or it absorbs the cost reducing profits in a low profit industry.

4 AGREE Comfortable that accommodation providers are responsible

This whole system looks cumbersome and onerous. We believe that the cost of administering the Visitor Levy will be more than the revenues collected. With such a cumbersome arrangement it is difficult to see much money being available to improve and maintain services in the areas effected by large amounts of visitors.

Scottish Community Tourism Network held a Zoom meeting to hear views. 14 people attended. 1 person agreed and 123 disagreed with this point. Comments made were: Breakout 1 • One social enterprise hotel, that is entirely run by volunteers, felt that they are already feel swamped by workload. This was seen as a tipping point. Another thing that accommodation provers will have to deal with. • An example was given of the closures of accommodation providers. When the Cateran Trail was set up there were 12 places to stay and now there are 6. Breakout 2 • There are 300 accommodation providers in Moray BID area. 75% against – lack of trust in council. Would an arm’s-length company administer the scheme better and be more trusted? • Time consuming for providers to maintain records and make returns – already busy enough and small providers don’t make big profits. • What if they’re pushed over threshold for VAT or other tax implications? • Administration for owners – levy should only be applied above a certain threshold/turnover (say £10k p/a?) Otherwise, seems like a lot of trouble to recoup very small sums. • Edinburgh – unfair treatment of accommodation providers is already causing ill-feeling. Breakout 3 • Needs to be more emphasis on rewarding people for complying, not punishing them for failing to do so. • This is going to be a significant extra burden and there needs to be incentives for complying. Accommodation providers need to see the benefits that will accrue to them. • Going to be a significantly greater detrimental impact on smaller providers. Bigger providers may be able to manage this, but it will be a huge administrative burden on smaller providers. May be forced out of the sector. • Don’t want to drive out community tourism. • Need to look at exemptions. • Would support an approach that discouraged greater absentee landlordism and encouraged more community providers.

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