The Principles of a Local Discretionary Transient Visitor Levy or Tourist Tax

4. The design of a visitor levy

This chapter sets out responses to the questions covering the different ways a visitor levy might apply to an overnight stay, how each option might affect accommodation users, accommodation providers and local authorities, whether the basis of the charge should be set out in a national framework or be for a local authority to decide, exemptions and the setting of a rate.

Basis of charge

The consultation paper set out a number of different ways a visitor levy might apply to an overnight stay in commercially let accommodation, seeking views on each basis of charging described. Views were also invited on whether the basis of the charge should be determined nationally, or should be for a local authority to decide.

Question 4: The consultation paper sets out four options for the basis of the charge. Please tick which one you think would work best in Scotland.

a) Flat rate per person per night

b) Flat rate per room per night

c) A percentage of total accommodation charge

d) Flat rate per night dependent on the quality of accommodation

Please provide a reason (or reasons) for your answer.

Responses to Question 4 by respondent type are set out in Table 5 below.

Overall, similar numbers of respondents who answered the question thought a percentage of the total accommodation charge (35%) or a flat rate per person per night (32%) would work best in Scotland. Fewer respondents advocated a levy based on a flat rate per room per night (24%) with even less support for a flat rate dependent on accommodation quality (9%).

There were marked differences between organisational respondents, who were most likely to opt for a flat rate per room per night charge (44%), and individuals, who most frequently chose a flat rate per person per night (42%).

Although many respondents opposed to any levy on accommodation did not answer Question 4, others did, often explaining their choice as the least undesirable of the options available to them. Those supporting the UK Hospitality related campaign (largely organisations in the Accommodation provider (hotel) group) generally selected a flat rate per room per night and accounted for around two in three of the organisations choosing this option. In contrast the Accommodation provider (other) group were most likely to prefer a percentage of total accommodation cost.

The 13 Local authority respondents who answered were evenly divided between flat rates per person, per room and a percentage of total accommodation.

Table 5

Question 4: The consultation paper sets out four options for the basis of the charge. Which do you think would work best in Scotland?
Respondent type	Flat rate per person per night		Flat rate per room per night		A % of total accommodation charge		Flat rate/night dependent on quality of accommodation		Not answered	Total
	N	%	N	%	N	%	N	%	N	N
Individuals	92	42%	23	11%	82	37%	22	10%	56	275
Accommodation provider (hotel)	3		42		2				2	49
Accommodation provider (other)	9		9		17		3		29	67
Business organisation	1		3						3	7
Community council or residents' association					3		1		1	5
Heritage or culture organisation	3		1		5		1		2	12
Local authority	4		4		5				9	22
Other			2		2				1	5
Other representative organisation	1				1		1		2	5
Other tourism or hospitality business or organisation	3		1		2				1	7
Port authority					1				2	3
Professional body			2		4				4	10
Public body	1								5	6
Tourism and hospitality industry representative organisation			2		4		1		3	10
Tourism development or promotion organisation	1		1		3		3		3	11
Trades union, political party or campaign organisation	2								3	5
Total organisations	28	18%	67	44%	49	32%	10	6%	70	224
All respondents	120	32%	90	24%	131	35%	32	9%	126	499

The analysis of further comments below is structured according by theme rather than by response to the closed question since many respondents made points both in favour of their preferred option and explaining their opposition to other methods.

Among general points that were raised across all the charging methods outlined on the consultation paper were that:

• The basis of a charge should either be at the discretion of a local authority or set out at a national level. This issue is explored further at Question 6.
• All options would create 'distortions and disruptions' for accommodation providers. A need for clarity over issues around set-up and ongoing costs to businesses was also argued, including with respect to VAT, commission charges, and charges on card payments.
• It is important that a 'level playing field' captures accommodation booked via all platforms and that the Scottish Government should introduce a comprehensive register of all commercially let accommodation.
• Tax rates that vary based on either guest-specific or accommodation-specific factors make it impossible for platforms to develop tools that correctly apply taxes based on the information provided by users. Uniformity is therefore important, with a need for one tax rate across all accommodation types.
• Out-of-season exemptions should be considered.
• For islands, transport-related options would be more appropriate than a charge on accommodation.

Flat rate per person per night

Among respondents who thought a flat rate per person levy would work best in Scotland, the most frequently given reason was that this would be the simplest or easiest to implement.

Some respondents simply suggested a flat rate per person to be fair while others argued that since individuals make demands on services, any charge should be per person. Respondents sometimes also noted that the stated principle of a visitor levy is to compensate for the impact of additional visitors. The need for any charge to be kept low was also suggested.

The use of this charging mechanism in other countries was highlighted and it was suggested that a per person charge will be clearer for guests.

Other points made in support of a flat rate per person levy included that it:

• Avoids penalising single travellers.
• Avoids the need for providers to check how many rooms are used, as would be necessary if a flat rate per room was charged.
• Avoids charging different rates for the same accommodation when room rates booked on different platforms vary, as would happen with a percentage charge.
• Would represent only a small increase on the total cost of a visit.

Respondents sometimes acknowledged that this method of charging would not work as well for families with children or in every type of accommodation, although an Other industry representative organisation respondent suggested that a flat rate per person could be easily linked to exemptions. Issues associated with verifying occupancy in self-catering properties were noted although it was also reported that some letting platforms do collect information on the number of guests. Potential variations suggested included:

• A flat rate based on the number of beds for self-catering properties.
• An alternative charging method for caravans and motorhomes.
• Only imposing a charge on adults or older children, although a view that charges should be irrespective of age was also expressed. Possible exemptions are covered further at Questions 11 and 12.

Respondents who highlighted what they saw to be negative aspects of a flat rate per person levy tended to argue that it would be regressive and unfair to those on low incomes with a related risk of damage to providers in the budget section of the market. A Professional body respondent suggested such a levy may not fit with the Scottish Government's approach to taxation. The tension between making a visitor levy easier to administer and reflecting ability to pay was noted.

Other possible drawbacks identified included:

• Potential for the system to be abused if visitors are not recorded accurately.
• Lack of seasonality.
• A need for periodic review to future proof the revenue stream since it will not increase with inflation. This was suggested to be poor use of local authority resources.

Flat rate per room per night

The most frequent reason given for using a flat rate per room charge was that this would be simple or the easiest to apply, with some respondents noting that the hotel industry convention is to charge per room per night. One Local authority respondent noted that, in their own consultation, a majority of respondents had indicated a preference for a flat rate per room per night.

Such a charging method was also argued to be fair and affordable, particularly for couples and families as well as being clear and simple to understand for guests.

The ability to confirm the charge based on the number of rooms let over a period was identified as a positive factor, and a flat rate per room was suggested to be less reliant on self-declaration by businesses, and less open to abuse.

Other advantages attributed to a flat rate per room per night included:

• It is a charging method used elsewhere.
• The rate will not fluctuate according to availability, seasonally or at weekends.
• It would avoid additional administrative burden for some providers, particularly those who operate a self-check-in system.

While some respondents noted that a flat rate charge of this kind would impose a higher burden on individuals with lower means it was also suggested that much of the levy will be paid by visitors from outside Scotland, and will be a charge on discretionary expenditure.

Among drawbacks identified as arising from a flat rate per room were that this:

• Is not related to ability to pay.
• Does not reflect seasonality.
• Would disadvantage single travellers.
• Is not a concept applicable to caravans or tents.
• Creates problems for self-caterers who may not know how many rooms will be used in a property.

Alternative suggestions included that for caravanning and camping, a pitch makes more sense than a room and for self-catering properties a charge could be on total capacity, or a per bedroom basis.

The legal definition of 'room' was also suggested to require extension to include 'key' for apartments or self-catering units, or 'bed' for hostels. It was noted, however, that a charge per bed would result in people staying in hostels paying disproportionately more relative to their accommodation price.

A percentage of total accommodation charge

Among respondents who preferred that a visitor levy should be based on a percentage of the total accommodation charge, the reason given most frequently was that this is fair and progressive – related to the ability to pay – since those choosing to use more expensive accommodation would also pay more tax.

A percentage charge was also suggested to be simple, straightforward or well understood, and to be a method of calculation that is already used elsewhere. It was however also acknowledged that a percentage may prove more complicated to calculate and to enforce than a flat rate.

A percentage of the total accommodation charge does not require accommodation providers to know how many people are staying in their accommodation. It was argued to be preferable for self-catering providers, for whom the number of guests staying at a property may be unknown or may be variable over the period of a booking.

Other points made in favour of a percentage charge included that it:

• Reflects changes in rates between high and low season.
• Reflects geographical variation in price.
• Will rise with inflation, reducing the need for periodic reviews.
• Broadly reflects the quality of accommodation since higher cost is likely to correspond to higher quality.
• Would be the best option for hostels where very low-cost accommodation is charged on a per-bed basis.

A need for clarity on what is meant by 'total accommodation charge' was also noted and views expressed on the inclusion, or otherwise, of 'extras' and commission charges in the figure on which the levy is calculated. Whether VAT would be payable on the levy was also queried and argued to be inappropriate since this would represent a tax paid on a tax.

Suggestions included that:

• Tax should be paid only on the basic fee not on food or other services.
• Tax should be charged on the total cost of the stay, including extras, or that not doing so could add complexity and administrative cost.
• If only charged on the basic fee, providers should not be allowed to minimise this and add extras in order to avoid tax.

It was also suggested that if a percentage charge were to be based on the total cost including extras, guests may be encouraged to spend as little as possible beyond their basic room rate.

A respondent indicated that the compatibility of this basis of charge with existing EU regulations should be considered, as it may potentially be viewed as a turnover or sales tax.

Although not specifically asked to do so, some respondents offered a view on the level of charge they would support, with suggestions including 1%, 2%, and 2.5%.

Respondents who argued against a percentage charge suggested that this is likely to:

• Result in a significantly higher cost for guests when compared to a flat rate per room.
• Disadvantage single travellers.
• Vary significantly and be very difficult to monitor and audit since room rates are so variable.
• Be incompatible with allowing exemptions.

A percentage charge was also suggested to have less visibility and feel like part of the overall cost, whereas a per head levy would be likely to be more visible.

Flat rate per night dependent on the quality of accommodation

Respondents who favoured a flat rate dependent on the quality of accommodation also argued this to be fair and progressive, with a higher rate for better accommodation reflecting the guest's ability to pay. It was also suggested that the lowest quality of accommodation could be excluded altogether.

Other points in favour of a rate dependent on quality of accommodation included that this would be easier to levy than a percentage charge and would be less open to manipulation.

However, the need for a single national grading system covering all accommodation was identified as a barrier to implementation of a system based on quality, both by respondents who favoured this option and those who made different choices.

Other arguments against a flat rate based on accommodation quality included both potential adverse effects for high cost accommodation providers if visitors choose cheaper options, and a lack of seasonality.

Alternative suggestions were:

• Flat rates with tiers based on accommodation cost.
• Flat rates based on the average room rate for the month of the charge.
• A flat rate per person per night, but with the rate determined by both the quality of the accommodation and the treatment of workers (e.g. paying the living wage).
• Flat rates according to accommodation type rather than as a reflection of quality.

It was also suggested that the consultation paper does not make clear whether a flat rate based on the quality of accommodation would be a flat rate per person or a flat rate per room.

Question 5: For each option in Question 4, what are the considerations for:

• Accommodation users?
• Accommodation providers?
• Local authorities?

General comments at Question 5 included both restated opposition to any of the options provided at Question 4 and observation that accommodation users will pay more than at present and that this could reduce discretionary spending or deter visitors altogether. For providers operating close to the border there were suggestions that potential guests might chose to take holidays in England instead. However, it was also argued that the levy proposed would add only a small addition to cost of accommodation and would represent a small proportion of the total cost of a visit.

Reduced business and additional administration costs for accommodation providers were identified as potential outcomes of any levy and an argument made that additional reporting and payment costs should be deductible as businesses expenses. Issues were raised specifically with respect to payment of commission to online booking platforms. How a charge might be included in an upfront booking costs and excluded from fees charged by a booking platform was queried.

Additional burdens associated with any VAT charged on the levy were also raised. For example, it was argued that if VAT is charged on the levy then businesses who are currently operating below the VAT threshold may be pushed over the threshold. One Professional body respondent suggested it to be likely that, where VAT applies, a visitor levy will form part of the base for calculating VAT and that this point should be covered in guidance for accommodation providers.

The need to ensure a level playing field, where a levy is imposed on all commercial accommodation however it is booked, was highlighted with a register of accommodation providers or a licensing requirement for providers proposed. The absence of a single database which contains details of all accommodation providers and so identifies all businesses liable to pay the levy was noted to create difficulties for collection.

A potential negative effect on the relationship between accommodation providers and guests was suggested by an Individual respondent, with issues raised including a risk of over-charging or lack of trust and suspicion of being over-charged, and potential reaction to an unexpected additional charge. An expectation among guests that providers will absorb a levy was also suggested and an information campaign to explain any visitor levy was argued to be necessary.

Exemptions were observed to add complexity to any system and that claiming exemptions will require guests to provide information or evidence regarding their personal circumstances. Exemptions are discussed further at Questions 11 and 12.

For local authorities the extra money available for investment in tourism was noted with a requirement for transparency over use of revenues and challenges associated with ensuring it is used for tourism both suggested. The need to produce visible results to justify charges was also argued as was the risk of negative publicity or reputational damage to a council introducing a levy.

Respondents also highlighted issues for local authorities in relation to collection of a levy including the cost of collection or enforcing non-payment, sometimes suggesting extra resources will be needed or that revenues raised may not cover costs of collection. It was argued both that authorities must be able to use some of the income from the levy on its collection and that legislation should set a maximum percentage that authorities can take from the levy fund to cover collection costs.

Requirements suggested for authorities tended to be applicable irrespective of the basis of a charge and included: collecting information on providers; receiving and processing data from providers; verifying the data provided; and setting up compliance processes including audits or inspections. A need for authorities to create and implement new systems to communicate with information providers was also suggested.

One Local authority respondent identified issues for consideration including: set up costs, registration of liable businesses, designing a legally competent scheme, providing guidance for businesses and communications to visitors, enforcement, dealing with non-compliance, validating and auditing of scheme.

Other suggestions included measures that might be taken to make compliance as easy as possible for providers:

• Scottish Government investment in an application programming interface (API) or plug-in to the most popular cloud-based booking application would help improve collection and reduce costs to providers.
• Attention was drawn to a nationwide e-Visitor programme used by accommodation providers in Croatia to register visitors and pay the visitor levy online.

Finally, it was noted that, for all charging options, work will be required to determine what the rate should be.

Flat rate per person per night

Implications for accommodation users

A levy based on a flat rate per person was argued to be simple to understand. It was also suggested that this form of charging is commonly used elsewhere and, provided that the rate set is low, is unlikely to deter potential visitors.

Other positive aspects identified included that a flat rate per person can readily be built into price of the stay, is easy for visitors to include in their budget, and is beneficial to single travellers. It was suggested it could be collected at booking, on arrival or on billing.

However, a flat rate per person was also argued to be regressive, not related to ability to pay, and to impose the highest percentage charge on those using budget accommodation while representing little additional cost to visitors staying in high end accommodation. A Local authority respondent suggested Scotland could be made less attractive to those on a budget as a result.

The potential impact of a flat rate per person charge on campsites was highlighted in particular, including that it could encourage wild camping rather than paying the levy at a campsite. A Tourism and hospitality industry representative organisation respondent questioned whether someone staying in low-cost accommodation (such as a holiday park) should pay the same rate as someone staying in a 5-star hotel.

A negative impact on those who share a room and also on family groups was suggested, unless children are exempt from the levy.

Other points included that:

• Visitors might not know the size of their party at the time of booking self-catering accommodation or that a charge per person could provide an incentive for guests to falsify occupancy details.
• Large self-catering properties could attract a high charge.
• Seasonal price adjustments will not be reflected, unless the rate varies by month.
• Check out may require extra time – for example for coach parties – if guests have to pay the charge individually.
• Online booking platforms often default accommodation searches to two people, which bookers generally do not correct when the number of guests is different. This has the potential to cause confusion and additional work at check-out if bills need to be corrected.

Implications for accommodation providers

Some respondents suggested a flat rate per person to be clear and easy to calculate, particularly when using automated systems. It was also noted to be straightforward with respect to individual exemptions. However, the need for extra administration and record keeping, including personal information, was also predicted and additional administration costs sometimes noted. Such costs were argued to be proportionately higher for small businesses and for those providing budget accommodation. Changes in booking processes were also suggested to be necessary for businesses who currently sell accommodation on a per room basis.

The need to record how many people stay each night was highlighted. Some respondents argued this to be straightforward – for example for hotels since knowing the number of guests is also a requirement for fire safety purposes. However, it was suggested to be difficult for self-catering providers whose accommodation is often booked online and who may have no on-site presence to check guest numbers. It was argued that the provider would be responsible for compliance, but dependent on the accuracy of information supplied by the guest. Further complexity was noted in that occupancy levels may fluctuate over the course of a booking. A fixed rate dependent on the number of beds was suggested as an alternative for self-catering properties.

A particular impact on providers of budget accommodation was argued to be likely if competitiveness is reduced and business is lost as a result. There was a suggestion that a provider might pay part or all of the charge themselves to avoid their accommodation being over-priced. Exclusion of lower cost accommodation from a levy in order to minimise these effects was suggested to be possible. An Accommodation provider (other) respondent argued that businesses offering low cost accommodation in southern Scotland might be affected particularly if potential visitors instead choose the Lake District to avoid a levy.

A per person charge was argued to be inappropriate for holiday parks that charge per unit, where knowing how many people are staying in tents, motorhomes and caravans might be impossible or be considered an invasion of privacy. Similar issues regarding occupancy of boats were raised with respect to marinas.

That caravaners and campers tend to tour a region was also noted as creating additional administration, while operation of seasonal pitches, where visitors may come and go as they choose without informing site management, was suggested to be incompatible with a charge per person per night.

A flat rate per person was also suggested to present a barrier to extending the length of the tourism season, with an Individual respondent noting existing challenges of attracting visitors at times of year when the weather may be inclement.

Implications for local authorities

For local authorities a flat rate per person was argued to be complicated or difficult to collect and police, and that authorities will be reliant on information from accommodation providers with scope for error or evasion as a result. It was suggested a flat rate per person or per room may need more in set up processes and mechanisms for providing an audit trail than required for a percentage charge.

Other respondents suggested a flat rate charge to be relatively simple to monitor and collect, to have no seasonal variation and to make income prediction easy. Information collected on the number of visitors to the area was also suggested useful with respect to planning for the future.

Loss of the potentially higher income predicted to arise from a percentage charge on more expensive accommodation was also suggested as a consequence of adopting a flat rate charge, depending on the make-up of the local accommodation market.

Other points on a flat rate charge per person charge included that it will not rise with inflation and that it could be applied only in periods of high demand.

Flat rate per room per night

Implications for accommodation users

For accommodation users a flat rate per room was suggested to be clear, simple or easy to understand and easy to budget for if identified at point of sale. It was also suggested to be an accepted charging method elsewhere and, for most visitors, to be likely to be the lowest cost option.

However, a flat rate charge was argued to be regressive, with guests paying the same levy on a room in affordable accommodation as in a 5-star hotel, and also to increase the burden on single travellers including business travellers.

While it was noted that, in comparison with a charge per person, a charge per room would be advantageous for families or groups sharing a room, a risk of encouraging overcrowding was also suggested.

Issues identified with respect to self-catering properties included that these would be difficult to monitor, and providers would be reliant on information from guests. A potential incentive to under-report room use to avoid a levy was suggested. However, it was also observed that while a flat rate charge on a self-catering property could be based on the number of rooms available this would result in under-occupancy of properties by small parties being penalised.

Implications for accommodation providers

A flat rate charge per room was argued to be the preferred option in hotels and other serviced accommodation where the industry convention is to set prices per room per night. It was suggested to be simple and easy to administer or to be the least difficult of the options presented.

A flat rate per room was suggested to be easier to apply to automated systems and online bookings and that use of platforms that collect tax for the provider might be encouraged by introduction of the levy. Nevertheless, it was argued there would be time and cost implications for providers, including updating property management systems and with respect to reporting and audit. A particular burden to small and micro businesses was suggested.

Questions were raised about how a charge per room per night would be applied. The need to clarify what would qualify as a room was highlighted in particular, with yachts, tents, yurts, glamping pods and touring caravans all given as examples where the concept would not be easy to apply.

As for a flat rate per person per night, a flat rate per room per night charge was suggested inapplicable to seasonal pitches on campsites. That such a charge would also be unfair to those who have purchased a static caravan on a holiday park site was argued.

Collecting information was on room occupancy was noted as an additional requirement that may be difficult for providers of self-catering accommodation where the number of rooms used might not be known until after guests have left. However, if a 'per key' charge was made on available rooms rather than rooms used, small groups might be asked to pay for rooms they do not use and be put off booking larger cottages as a result. Alternatively, it was argued accommodation providers might under-specify the number of rooms, leading to a reduction in large properties visibly available to rent.

A rate per room was suggested likely to encourage overcrowding and potential safety issues. It was also argued single rooms would become unattractive and might be turned into doubles.

Loss of businesses for providers of lower cost accommodation and fewer bookings for self-catering properties were both predicted.

Implications for local authorities

A flat rate per room was suggested to be relatively easy to enforce including because only the number of rooms occupied would need to be declared and that room number can be included in registration. An Accommodation provider (hotel) respondent suggested that alignment of data collection to the Scottish Assessors Association (SAA) returns would make verification easier.

Income for authorities was predicted to be lower than that raised by other schemes but to be easiest to forecast for budget purposes and at a lower risk of fraud.

The need for clarity on which rooms are chargeable was noted.

A percentage of total accommodation charge

Implications for accommodation users

A percentage charge was argued to be fairer than a flat rate levy for accommodation users since it would mean visitors staying in more expensive accommodation would pay more than those choosing cheaper options.

However, a percentage charge was also viewed as penalising more expensive accommodation and to have an adverse impact for single travellers for whom prices are generally higher in any case. It was argued that the stated purpose of the levy is to cover the cost of providing services for individuals, and the price of the accommodation used is not related to the burden on infrastructure.

There were two contrasting perspectives on how easy a percentage charge might be for users:

• That it would be clear and easy to understand.
• That it is complicated or more difficult to understand. In contrast, a flat rate charge was argued to provide certainty.

Additional points raised by those who felt a percentage charge to be complicated included that both seasonal variation and the effects of dynamic room pricing could be confusing, and that it may also be difficult to understand which elements are being taxed. As a result, it may be harder to budget and guests may be faced with unexpected additional fees.

It was argued that the charge must be identified at point of sale however booked. Nevertheless, the effect of dynamic room pricing was suggested to mean the levy charged would vary from day to day or according to which booking method is used. An Accommodation provider (other) respondent argued that the likely outcome that different people would pay a different levy charge for the same standard of accommodation, in the same place and on the same night at that this would be unfair.

Seasonal price variation and hence variation in the levy paid was noted and generally seen as positive since off-season use would be cheaper but was sometimes viewed as greater cost in high season. It was also suggested that users might be pushed towards less expensive accommodation during high season.

A general risk that users may look elsewhere for cheaper options, including elsewhere in the UK, was also identified. It was also argued that, in some circumstances, a percentage charge could add a large amount to the cost of a holiday.

Making higher quality accommodation more expensive or unaffordable especially in high season was noted as a potential outcome of a percentage charge and that this would apply generally in more expensive locations such as Edinburgh. A potential impact on corporate customers was identified.

Other respondents suggested the level of charge to be important or argued that only a small percentage should be charged.

Although a percentage charge was argued to favour the self-catering sector over more expensive serviced accommodation, it was also suggested that, if paid per property, a percentage levy would be unfair to those who under-occupy a large property.

Implications for accommodation providers

A percentage charge was suggested to be easy to administer or to be easy for those using automated systems or operating via agencies and booking platforms who would collect the levy. It was noted operators are used to paying platform fees based on a percentage of the accommodation charge, so the form of the levy is well understood.

However, a percentage was also argued too complicated or difficult to administer both adding to costs and requiring changes to current practices.

Issues highlighted as adding complexity included:

• Packages including meals or other extras in addition to the room.
• Dynamic pricing and use of multiple booking platforms.
• Calculation of exemptions, particularly in mixed groups.
• Application of discounts.

On the first point it was argued that it must be made clear to what elements a percentage levy applies. While it was observed to be challenging to separate the elements of a bill, it was also argued that a levy applied to the total bill rather than just the room charge would discourage visitors from eating and drinking in a hotel.

Although noted to be fairer for budget operators, a percentage charge was argued to have potentially adverse impacts for providers of high cost accommodation if users chose cheaper alternatives and there is pressure to cut prices. Although a percentage charge was argued to act as a proxy for quality of accommodation it was also noted that in remote or island locations hotels may have higher costs and lower margins and that, in general, high quality accommodation has a higher cost base and is not necessarily more profitable.

A small number of Accommodation provider (hotel) and Accommodation provider (other) respondents and a Tourism development or promotion organisation respondent and were amongst those suggesting the burden for small providers would be disproportionate, especially for those operating under the VAT threshold who may find it hard to adjust their current practices. It was noted that in some areas the sector is characterised by a high number of small providers.

Implications for local authorities

For local authorities a percentage charge was argued to be easy to monitor by some respondents. Suggestions included that a levy could be based on sales income, checked against tax returns or, more specifically, linked to a ratio of the VAT payment.

Respondents who thought a percentage charge likely to be difficult to monitor sometimes pointed to a requirement for more information from providers and the number of variables involved. A percentage charge was suggested to be open to greater error or manipulation and to create a high administrative burden on authorities.

Potentially higher revenue raised from a percentage charge was noted, including higher returns from more expensive accommodation, although caution was suggested since income would fall if too high a rate is imposed in an area with a lot of high-quality accommodation. It was also argued that revenues may not cover collection costs for low cost accommodation. Exclusion of smallest providers from charging the levy was suggested.

Difficulty in forecasting revenues from a percentage charge was predicted since tax take will fluctuate as a result of changing nightly fees and last-minute discounts in addition to seasonal variation. It was suggested to be worth considering how a levy would be applied over a year ahead of its implementation in order to provide authorities with a likely baseline for revenue expectation.

It was also noted that local authorities will need to know what part of the accommodation price attracts levy and that consideration should be given to the definition of 'accommodation charge' to guard against avoidance arising from the charge being broken down into multiple elements with some not being within the scope of the levy.

Unlike flat rate charges, a percentage charge would rise with inflation.

Flat rate per night dependent on the quality of accommodation

Implications for accommodation users

It was suggested that, for accommodation users, a flat rate dependent on the quality of the accommodation would be fair or progressive since those selecting higher quality accommodation would pay more. However, it was also argued that the services used by visitors are not related to the quality of the accommodation they choose.

It was also thought that a flat rate dependent on quality could be complicated or confusing for accommodation users including because there is no universally accepted rating system, and that the relationship between accommodation price and quality rating is not universal. For example, it was argued that a 3-star hotel in an expensive location might charge a higher daily rate but a lower visitor levy than a 4-star hotel in a cheaper area. Difficulties in comparing island and mainland establishments were also highlighted. Flat rates with tiers dependent on the price of a room rather than the quality of the accommodation were proposed as an alternative.

Respondents suggested that visitors may choose lower rated accommodation in response to a levy charged on this basis, leading to negative impacts at the higher end of the market.

Implications for accommodation providers

As set out in the consultation document, respondents acknowledged that there is currently no single accommodation standard in Scotland. Respondents commented further that existing grading schemes use different criteria so are not comparable, and that some businesses rely entirely on online reviews and are not part of any formal grading system. Costs associated with grading were identified in addition to generally increased administrative burden incurred by providers.

Comments on existing rating systems included that these sometimes reflect the facilities provided rather than quality per se or that the quality of the product does not always relate directly to price. Perception of 'quality' was also argued to be personal or subjective.

A number of Accommodation provider (other) respondents argued that charging a levy based on accommodation quality would be unworkable for holiday parks, where existing grading depends on the park overall rather than individual accommodation provided, and where a wide range of accommodation types and quality may be available on a single site. It was also noted that other providers might have, for example, hotel and self-catering accommodation available on one site and that consideration would be required as to the approach to be taken in such circumstances.

While a levy based on quality of accommodation was argued not to disadvantage providers of budget accommodation it was also thought likely to deter provision of higher quality accommodation, or to incentivise lower quality. A Tourism and hospitality industry representative organisation respondent commented that this may be a disincentive to businesses wanting to invest in providing better quality accommodation if their guests will be charged more in a visitor levy.

Other general points on the implications for providers included that this basis for charging would:

• Reduce the need to declare financial information in comparison with a percentage charge.
• Be unfair for rural providers who are likely to be empty over the winter.

Implications for local authorities

Respondents suggested local authorities could be presented with a significant administrative burden particularly associated with implementation and monitoring of a quality rating system. It was also anticipated that there would need to be a system for appeals if providers felt they had been graded incorrectly.

There were apparently differing expectations of how a monitoring system might be set up. While some respondents expected local authorities would do so, others:

• Queried who would be responsible for grading accommodation, or which grading scheme would be used.
• Highlighted a need for existing grading systems to provide consistency of ratings.
• Suggested that providers might not register, might withdraw from schemes, or might self-declare a lower standard in order to avoid the levy or to charge a lower rate.

The need for a statutory system was argued, including by several Local authority respondents, with one of these respondents suggesting the VisitScotland quality grading system should become mandatory. Whether regions might vary was queried and a need for national standards was proposed.

Other aspects highlighted as likely to arise from this basis for charging included that:

• Returns from providers will be complex and potentially inaccurate or open to under reporting.
• Revenue may be difficult to forecast for budget purposes.
• There may be higher revenue in areas with more high-quality accommodation, but also that this will be lost if the higher end of the market is damaged.
• Local authorities would be provided with an incentive to enforce regulations across the sector as a whole.

Question 6: Do you think that the basis of the charge should be set out in a national framework, or be for a local authority to decide?

Please provide a reason (or reasons) for your answer.

Responses to Question 6 by respondent type are set out in Table 6 below.

A majority of respondents, 65% of those answering the question, thought that the basis of the charge should be set out in a national framework. Organisations were more likely to favour the national framework-based approach than individuals (75% and 57% respectively).

Local authority and Trades union, political party or campaign organisation respondents were the only categories in which a majority of respondents thought the basis of the charge should be for a local authority to decide.

Table 6

Question 6: Do you think that the basis of the charge should be set out in a national framework, or be for a local authority to decide?
Respondent type	Set out in a national framework		Decided by local authorities		Don't know		Not answered	Total
	N	%	N	%	N	%	N	N
Individuals	134	57%	79	33%	23	10%	39	275
Accommodation provider (hotel)	46		2		1			49
Accommodation provider (other)	45		14		1		7	67
Business organisation	4		1				2	7
Community council or residents' association	2		2				1	5
Heritage or culture organisation	6		1		2		3	12
Local authority	8		10		2		2	22
Other	2		1				2	5
Other representative organisation	2		1				2	5
Other tourism or hospitality business or organisation	4		2				1	7
Port authority	1				1		1	3
Professional body	6		1				3	10
Public body	2						4	6
Tourism and hospitality industry representative organisation	8		1				1	10
Tourism development or promotion organisation	8		2				1	11
Trades union, political party or campaign organisation			3				2	5
Total organisations	144	75%	41	21%	7	4%	32	224
All respondents	278	65%	120	28%	30	7%	71	499

Set out in a national framework

The themes raised by respondents who thought that the basis of the charge should be set out in a national framework very much reflected those expressed by respondents who thought that the design of a visitor levy should be set out on wholly in a national framework (option a at Question 1).

For some, the focus was on ensuring there is a clear and consistent approach across the country and that this in turn would help avoid confusion. There were specific references to not creating confusion amongst visitors, and for those moving around Scotland or amongst international visitors in particular. It was also suggested that those affected by a tax are less likely to trust it if it varies substantially and that a consistent national model is more likely to be accepted.

Other comments addressed fairness and suggested that the basis of the charge being set out in a national framework could help avoid competition between local authorities and distortions developing in the tourism market. In particular, it was noted that accommodation providers located very close to each other, but on different sides of a local authority boundary, could be subject to very different regimes and that these variations could have a significant impact on their competitiveness and ability to attract visitors. A specific example given of the potential for distortion was large events being able to negotiate for a visitor levy to be covered by subvention funding, thereby becoming an additional local cost to an event organiser or accommodation provider, rather than the visitor.

Issues relating to distortions in the market were often linked to the impact of variations in approach on businesses that operate across more than one local authority. The administrative complications arising for businesses operating across a number of local authorities of having to work to different arrangements were also highlighted and it was suggested that limited variation would make is easier and more desirable for businesses to expand their business into new local authority areas.

In terms of preferred solutions, it was suggested that the national framework should include a nationally agreed formula that recognises different local needs. An example given was giving discretion to remove or reduce the levy over the off-peak season.

Other reasons given for supporting the basis of the charge being set out in a national framework included that Scottish Ministers would retain a strong interest in the development and ongoing operation of new local taxation systems. It was also suggested that this approach would allow for a digital tool, similar to current tools such as the NDR calculator, to be developed by the Scottish Government to assist businesses to calculate charges and payments.

Many of the other comments raised focused on the rate of the levy and are covered at Question 7 below.

Decided by local authorities

The themes raised by respondents who thought that the basis of the charge should be decided by local authorities also reflected those expressed by respondents who thought that the design of a visitor levy should be mostly at a local level or mostly at a national level with some local discretion (options c and b at Question 1).

Comments tended to be brief but included that a one-size-fits-all approach would not be fit-for-purpose and that local authorities are best placed to develop arrangements appropriate to local circumstances. The diversity of Scotland's tourism market and communities were again highlighted, including with reference to the particular circumstances applying to island communities.

It was also noted that a local authority led approach allows for communities and local businesses to have more influence over the design of something that would impact on them directly.

Calculating the rate

The consultation sought views on whether the rate of a visitor levy should be set nationally or determined locally and on what, if any, national oversight might apply if decisions about the rate of visitor levy were made locally.

Question 7: Do you think that the rate of the visitor levy should be set out in a national framework or should it be for the local authority to decide?

Please provide a reason (or reasons) for your answer.

Responses to Question 7 by respondent type are set out in Table 7 below.

A majority of respondents, 57% of those answering the question, thought that the rate of the visitor levy should be set out in a national framework. Organisations were more likely to take this view than individuals (67% and 49% respectively).

The majority of Local authority, Business organisation and Trades union, political party or campaign organisation respondents thought the rate of visitor levy should be for the local authority to decide.

Table 7

Question 7: Do you think that the rate of the visitor levy should be set out in a national framework or should it be for the local authority to decide?
Respondent type	Set out at national level		Decided by local authorities		Don't know		Not answered	Total
	N	%	N	%	N	%	N	N
Individuals	124	49%	101	40%	28	11%	22	275
Accommodation provider (hotel)	44		3		1		1	49
Accommodation provider (other)	47		11		2		7	67
Business organisation	2		3				2	7
Community council or residents' association	2		2				1	5
Heritage or culture organisation	4		4		2		2	12
Local authority	5		15				2	22
Other	2		1				2	5
Other representative organisation	2		1				2	5
Other tourism or hospitality business or organisation	4		3					7
Port authority	2		1					3
Professional body	4		4				2	10
Public body	1		1				4	6
Tourism and hospitality industry representative organisation	7		2				1	10
Tourism development or promotion organisation	5		4		1		1	11
Trades union, political party or campaign organisation			3				2	5
Total organisations	131	67%	58	30%	6	3%	29	224
All respondents	255	57%	159	35%	34	8%	51	499

4.47 As at Question 6, comments tended to raise similar themes to those covered at Question 1. The analysis presented below focuses on new matters arising.

Set out in a national framework

Reasons given for favouring the rate of the visitor levy being set out in a national framework included that the approach would:

• Bring decisions within the remit and responsibility of MSPs.
• Meet the Scottish Approach to Taxation principle of certainty. Accommodation provider (other), Tourism and hospitality industry representative organisation respondents and Individual respondents were amongst those expressing this view.
• Allow for the cumulative effect of taxes on Scotland's competitiveness as an international destination and businesses to be taken into account.

Other comments focused on why respondents did not favour local authorities being able to decide the rate and included that they may be tempted to use a visitor levy simply as a means of raising additional general funds. There was also a concern that the rate set by one local authority could affect more than their own area and could have an adverse impact on the national economy.

There was a view that there is not necessarily shared experience across a whole local authority area. It was proposed, for example, that trials of different models of operation should be carried out on a variety of islands of different sizes and across the relevant local authorities with island communities. It was suggested that this would allow island interests to be informed stakeholders in shared decision making concerning appropriate levels of local levies, as well arrangements for collecting revenues.

In terms of the overall approach to be used, it was suggested that the national framework should set out a range within which a rate could be set, but then allow for local discretion as to the precise rate set. However, there as an associated concern that local authorities would be likely to charge the maximum permitted.

Decided by local authorities

Comments were limited but included that the rate being for a local authority to decide would allow:

• The rate to be set in response to a specific local tourism initiative.
• Regional business forums, Destination Management Organisations (DMOs), residents or workers to be more directly involved in the setting of the rate.

A Local authority respondent suggested that the approach would be in line with the joint agreement between COSLA and the Scottish Government to focus on and strengthen local and community decision-making and democratic governance.

In terms of concerns about setting out the rate in a national framework, it was suggested that affordability and accommodation price differs greatly between areas and that a national agreed rate would be restrictive and disadvantageous to some areas.

Question 8: What factors should be considered to ensure the rate of the visitor levy is appropriate?

Please provide a reason (or reasons) for your answer

A number of the comments at Question 8 reflected the general objections raised to the introduction of any visitor levy (as covered at the beginning of Chapter 3). For example, it was suggested that factors to be considered to ensure the rate of the visitor levy is appropriate should include the competitiveness and reputation of Scotland as a tourism destination, the wider tax regime, including VAT rates, and the likelihood of a decrease in the number of visitors or a reduction in average lengths of stay.

A general theme raised was the need for any decisions to be based on proper investigation and robust evidence, and there were calls for independent economic impact assessments or industry impact assessments to be carried out.

Other comments addressed the local market circumstances which should be considered, with suggestions including:

• The role of tourism within the local economy.
• The number of local attractions.
• Sensitivity of the local tourism market to price increases.
• Visitor numbers and the demographic profile of those visitors, including their ability to pay a levy.
• Affordability, including the costs to reach a destination.
• Visitor spend, and consumer price sensitivity.
• Seasonal variations.
• The impact of major festivals or events.

There were also suggestions as to factors specifically relating to accommodation that should be considered. These included:

• The profile of the accommodation sector locally, including its size, and the type and availability of accommodation.
• Demand and occupancy rates by accommodation type.
• Price of accommodation and variance in price.
• Likely response of accommodation users.

Other comments considered the impact that tourism has on a local area and included:

• The impact of tourism on communities, including on the cost of living for locals.
• The impact on infrastructure.
• The direct costs of tourism to an area, for example through increased water use or the need for additional refuse collections. Specifically, clean-up costs.

A specific suggestion was that there should be a benchmarking of the rate to other rates being charged by:

• Neighbouring local authorities.
• Other areas in Scotland.
• Other parts of the UK.
• Other tourist destinations or countries or, specifically, with other European or EU cities or countries.

It was also suggested that any benchmarking should include a comparison of total taxes paid.

Other comments focused on the balance between the cost of administering a levy for the local authority, and the cost to businesses of collecting the levy, relative to the revenues obtained. There was a view that any approach must be economically worthwhile and provide a significant enough surplus to invest to support the sector and affected communities. In terms of that surplus, it was suggested that there being strategically planned investment in the tourism sector should also be a factor to be considered.

Finally, and very much reflecting issues covered at later questions, respondents suggested that consulting with local communities, businesses and stakeholders will be important.

Question 9: If the rate of the visitor levy were to be set by individual local authorities, should an upper limit or cap be set at a national level?

Please provide a reason (or reasons) for your answer

Responses to Question 9 by respondent type are set out in Table 8 below.

Table 8

Question 9: If the rate of the visitor levy were to be set by individual local authorities, should an upper limit or cap be set at a national level?
Respondent type	Set out at national level		Decided by local authorities		Don't know		Not answered	Total
	N	%	N	%	N	%	N	N
Individuals	172	72%	42	18%	24	10%	37	275
Accommodation provider (hotel)	11		1				37	49
Accommodation provider (other)	50		6		2		9	67
Business organisation	4						3	7
Community council or residents' association	1		2		1		1	5
Heritage or culture organisation	7		2		1		2	12
Local authority	6		12		3		1	22
Other	3		1				1	5
Other representative organisation	2		1				2	5
Other tourism or hospitality business or organisation	5		1				1	7
Port authority	2						1	3
Professional body	4		1		1		4	10
Public body	1						5	6
Tourism and hospitality industry representative organisation	9						1	10
Tourism development or promotion organisation	9		1				1	11
Trades union, political party or campaign organisation	1		2				2	5
Total organisations	115	75%	30	20%	8	5%	71	224
All respondents	287	73%	72	18%	32	8%	108	499

A majority of respondents, 73% of those answering the question, thought that if the rate of the visitor levy were to be set by individual local authorities, there should an upper limit or cap be set at a national level. Organisations were slightly more likely than individuals to take this view (75% and 72% respectively).

Local authority, Community council and Trades union, political party or campaign organisation respondents were the only groups in which a majority did not favour there being an upper limit or cap be set at a national level.

Further comments at Question 9 generally raised similar themes to those covered at Questions 1, 6 and 7.

Set out at a national level

Comments tended to focus on ensuring any approach supports competitiveness across the whole of Scotland's tourist industry, including by reflecting the cumulative effect of local taxes, and does not lead to regional or local distortions that unfairly impact on some businesses. The issue of clarity and adopting an approach that is easy and straightforward for visitors to understand was also raised.

There were also some concerns about whether local authorities could be guaranteed to make reasonable or informed decisions about the rate of any levy. On the latter point it was suggested that not all local authorities understand the tourism market or the way tourism businesses operate. There was also a concern that some local authorities could be 'greedy' and prefer to tax local businesses and visitors rather than make other unpalatable decisions relating to increasing their revenue or reductions in local services.

Decided by local authorities

Those who did not favour an upper limit or cap being set at a national level sometimes commented that local circumstances should determine the appropriate charging rate and that such an approach is consistent with maximising local autonomy and the promotion of local democracy.

Other issues raised included that local authorities would not take decisions that are detrimental to local economic growth or the local tourist industry.

Exemptions

The consultation paper set out a number of groups for whom it was thought to be unacceptable to impose a visitor levy under any circumstances including: homeless people; asylum seekers and refugees; travelling communities; and victims of domestic abuse placed temporarily in refuges or short term accommodation.

Beyond these groups, other groups could be included for exemption either at the national or local level.

Question 10: Do you think that all exemptions should be the same across Scotland and therefore set out in the national legislation, or should local authorities have scope to select some exemptions?

Responses to Question 10 by respondent type are set out in Table 9 below.

A majority of those who answered the question, 78%, thought that all exemptions should be the same across Scotland and therefore set out in the national legislation. Local authority respondents were among the groups that were relatively evenly divided on whether the exemptions should be set out in the national legislation, or whether local authorities should have scope to select some exemptions.

Table 9

Question 10: Do you think that all exemptions should be the same across Scotland and therefore set out in the national legislation, or should local authorities have scope to select some exemptions?
Respondent type	All exemptions should be the same across Scotland and local authorities should not have any discretion.		Some exemptions should be set at national level, and some should be at the local authority's discretion		Not answered	Total
	N	%	N	%	N	%
Individuals	183	81%	44	19%	48	275
Accommodation provider (hotel)	10		3		36	49
Accommodation provider (other)	49		4		14	67
Business organisation	3		1		3	7
Community council or residents' association	1		3		1	5
Heritage or culture organisation	5		5		2	12
Local authority	9		10		3	22
Other			1		4	5
Other representative organisation	1		2		2	5
Other tourism or hospitality business or organisation	3		1		3	7
Port authority	1		1		1	3
Professional body	4		1		5	10
Public body	1				5	6
Tourism and hospitality industry representative organisation	6				4	10
Tourism development or promotion organisation	9		1		1	11
Trades union, political party or campaign organisation			3		2	5
Total organisations	102	74%	36	26%	86	224
All respondents	285	78%	80	22%	134	499

Question 11: Which additional exemptions from the list below do you think should be applied to a visitor levy?

Responses to Question 11 by respondent type are set out in Table 10 below.

Respondents were asked to identify which of a range of possible additional exemptions they thought should be applied to a visitor levy. The proportion thinking an exemption should be applied ranged from 62% to 25% of all respondents^[9]:

• At 62%, the highest level of support was for an exemption for those receiving medical care outwith their local authority area and their carers or next of kin. Whilst 72% of individuals favoured this exemption, support dropped to 50% of organisations.
• A small majority of respondents favoured there being exemptions for children and young people or for local residents (53% and 52% respectively). Again, a higher proportion of individual respondents expressed support (56% and 61% respectively), than did organisations (48% and 41% respectively).
• Three exemptions were supported by a large minority of respondents: disabled people, those registered blind and deaf, and their carers (46% of all, 49% of individuals and 42% of organisations); students (40% of all, 44% of individuals and 37% of organisations); and long stay guests (40%, 40% of individuals and 40% of organisations). The pattern of support for long stay guests was relatively unusual in that is was made up of equal proportions of both individuals and organisations.
• The lowest level of support was for business travellers being exempt. Only 25% of respondents thought an exemption should apply (28% of individuals and 22% or organisations).

Table 10

Question 11: Which additional exemptions from the list in the consultation paper do you think should be applied to a visitor levy?
Respondent type	Disabled people and registered blind/deaf and their carers		Those travelling out with their local authority area for medical care, their carers or next of kin		Children and young people under a certain age		Students		Total
	N	%	N	%	N	%	N%	%	N
Individuals	136	49%	199	72%	155	56%	120	44%	275
Accommodation provider (hotel)	8		12		11		8		49
Accommodation provider (other)	41		49		48		40		67
Business organisation	3		4		2		1		7
Community council or residents' association	3		3		2		1		5
Heritage or culture organisation	7		7		7		7		12
Local authority	9		11		10		6		22
Other	1		1		2		2		5
Other representative organisation	3		2		2		1		5
Other tourism or hospitality business or organisation	2		4		5		1		7
Port authority	2		2		2		1		3
Professional body	3		3		3		3		10
Public body									6
Tourism and hospitality industry representative organisation	7		6		6		5		10
Tourism development or promotion organisation	4		6		5		5		11
Trades union, political party or campaign organisation	2		2		2		1		5
Total organisations	95	42%	112	50%	107	48%	82	37%	224
All respondents	231	46%	311	62%	262	53%	202	40%	499

Table 10 (continued)

Question 11: Which additional exemptions from the list in the consultation paper do you think should be applied to a visitor levy?
Respondent type	Long stay guests (e.g. people staying for more than 14 days)		Business travellers		Local resident (paying for overnight accommodation within the local authority in which they reside permanently)		Total
	N	%	N	%	N	%	N
Individuals	111	40%	77	28%	167	61%	275
Accommodation provider (hotel)	10		8		10		49
Accommodation provider (other)	41		18		44		67
Business organisation	2		2		2		7
Community council or residents' association	1				4		5
Heritage or culture organisation	7		2		6		12
Local authority	7		6		7		22
Other	1		1		1		5
Other representative organisation			1		1		5
Other tourism or hospitality business or organisation	2		1		2		7
Port authority	2		2		2		3
Professional body	1				1		10
Public body							6
Tourism and hospitality industry representative organisation	8		2		6		10
Tourism development or promotion organisation	7		5		5		11
Trades union, political party or campaign organisation	1		1		1		5
Total organisations	90	40%	49	22%	92	41%	224
All respondents	201	40%	126	25%	259	52%	499

Question 12: Are there any other exemptions that you think should apply? Please list together with reasons.

There were relatively few suggestions for other exemptions, and further comments, including giving reasons, tended to be brief.

The possible other exemptions proposed were:

• Those resident in Scotland. Supporting reasons given included that Scottish residents are already paying for services in their own area, that movement of Scottish residents around the country will balance out to some extent and that people should be encouraged to 'staycation' in Scotland.
• Anyone resident in the UK, for similar reasons to those outlined above.
• Residents travelling inter-island, for example in Shetland.
• Workers in the NHS, emergency services and education for whom a quality holiday is essential and against which local authorities should place no barriers.
• People on low incomes, including low income families or those living on a pension. One suggestion was that receipt of certain benefits could be used as a proxy for being eligible for an income-based exemption.
• People visiting family or friends, including if staying in otherwise chargeable accommodation but at no charge. Also, owners staying in their own accommodation, particularly if they are there to carry out maintenance.
• If there is connection to a charity or not for profit organisation, for example if a stay or journey is as part of a youth group such as Scouts and Guides or if participating in a Duke of Edinburgh award scheme trip. Also, anyone travelling or staying in order to carry out volunteer work for a charity or not for profit organisation.
• Sports groups travelling to compete in regional or national events.
• People affected by incidents which force them to leave their homes, such as flooding.
• People under witness protection or utilising safe rooms.
• Those visiting during the tourism low season.
• People whose travel arrangements have been disrupted, for example by ferry cancellations during bad weather.

Other comments focused on the practical issues associated with applying exemptions, for example in terms of gathering the necessary evidence to demonstrate an exemption applies. The importance of avoiding unintended negative consequences, including stigmatising vulnerable groups by forcing self-declaration, was also highlighted. A suggestion was that a local authority might design an initial registration process where commercially let accommodation providers who provide statutory accommodation for people in vulnerable circumstances would identify themselves to the relevant local authority.