Item 11 - Appendix 2
West Dunbartonshire Council · 12 November 2025
Back to Infrastructure, Regeneration & Economic Development Committee — 12 November 2025 and its agenda
Text extracted from the council's PDF. Layout and reading order may differ from the original.
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Report – Appendix 2 1 West Dunbartonshire Council Visitor Levy Formal Consultation Findings Report November 2025 West Dunbartonshire Council Council Offices 16 Church Street Dumbarton G82 1QL ITEM 11- APPENDIX 2
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Report – Appendix 2 3 Contents Introduction 3 Press Release 3 Social Media 3 On-line Survey 4 Tourism Stakeholder Meetings 8 Federation of Small Businesses/Dunbartonshire Chamber of Commerce 8 Loch Lomond & Trossachs National Park engagement session 8 Local Hotels Engagement Session 10 Industry Focus Groups 10 An Industry Response – Name and Business Details Provided 12 An Industry Response - Accommodation Provider (Anonymous) 14 Evening Drop-in sessions 15 Conclusion 15 Appendix 1: West Dunbartonshire Council Visitor Levey Stage 1 Survey Summary Results 18 Appendix 2: Loch Lomond and the Trossachs National Park Authority – Response to the West Dunbartonshire Council Visitor Levy Consultation 22 Appendix 3: Visit Scotland – Response to the West Dunbartonshire Council Visitor Levy Consultation 27 Appendix 4: Federation of Small Businesses – Response to the West Dunbartonshire Council Visitor Levy Consultation 39
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Report – Appendix 2 4 Introduction The Scottish Parliament passed the Visitor Levy (Scotland) Bill on 28 May 2024. The visitor levy is a local tax, which means that the Scottish Parliament has passed powers to local councils across Scotland to decide whether to impose a levy on visitors to their area. In West Dunbartonshire, it is recognised that a visitor levy represents a significant opportunity to generate an additional recurring annual income stream (estimated £1.7M) to sustain and support the facilities and services substantially used by visitors for leisure and business purposes within the local area. A stage 1 consultation survey was carried out over a 6-week period, from 20 January to 28 February 2025. To raise awareness, an e-mail providing further details and a link to the on-line survey was sent out directly to all short term let licence holders and a press release was also published by the Council’s Corporate Communications team. The survey was also shared with tourism organisations such as Visit Scotland, Loch Lomond & Trossachs National Park and Love Loch Lomond. There were 563 responses to the survey. Overall, respondents to the stage 1 survey were not supportive of introducing a visitor levy within West Dunbartonshire. In total, 73% of respondents strongly disagreed/disagreed with the implementation of a visitor levy. Only 22% of respondents showed general support for introduction of a levy with 5% neither agreeing nor disagreeing. A copy of the results from the stage 1 survey is available for information at Appendix 1. The stage 2 formal consultation to consult on West Dunbartonshire’s draft visitor levy proposals ran from 28 July 2025 – 21 October 2025 and consisted of a press release, social media posts, an on-line survey, tourism stakeholder meetings, National Park engagement session, local hotels engagement session, industry focus group and evening drop-in sessions. This report provides a summary of the findings of the stage 1 and formal stage 2 consultation regarding the potential implementation of a visitor levy in West Dunbartonshire. Press Releases To raise local awareness at both stage 1 and stage 2 of the consultation process press releases were published and copies of these are available at Appendix 5 and the links below. Visitor Levy Stage 1 Press Release Visitor Levy Stage 2 Press Release Social Media During the consultation process the Council’s Corporate Communications team assisted with the promotion of the link to the on-line surveys and the draft proposals. In total, 5 posts with a combined total reach of 58,500 were put out through the Council’s corporate social media channels. These social media posts generated 328 reactions, 617 comments and 59 shares. The comments received were generally not supportive of a visitor levy with the main reasons being concerns that a visitor levy would deter visitors from coming to the local area and comments relating to the
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Report – Appendix 2 perception that the local area does not have a sufficient offer to charge visitors a levy to stay. On-line survey A Stage 2 on-line survey was developed and ran from 28 July – 21 October 2025. The survey gathered feedback on the draft proposals from accommodation providers, businesses, members of the public and visitors to the local area. The results from the stage 2 survey can be found below.
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Report – Appendix 2 Tourism Stakeholder Meetings Individual meetings were offered/arranged with representatives of tourism partner organisations such as Visit Scotland, Loch Lomond & Trossachs National Park, Association of Scotland’s Self Caterers and Love Loch Lomond to make them aware of the stage 2 consultation and obtain feedback on the draft proposals. An officer met with Visit Scotland, Loch Lomond & Trossachs National Park and Love Loch Lomond to discuss the proposals. The Loch Lomond & Trossachs National Park provided a formal response to the stage 2 consultation which is provided in Appendix 2. Visit Scotland have also provided a formal response to the consultation which is available in appendix 3. The Association of Scotland’s Self Caterers shared correspondence on behalf of the Scottish Tourism Alliance, which was sent to the Minister for Public Finance, Ivan McKee, on 5th August 2025. The Scottish Tourism Alliance letter set out the industry’s concerns about the roll-out of the Visitor Levy in its current form, it also included a risk matrix, which highlights some of the perceived potential pitfalls and outstanding questions in relation to FAQ’s. Federation of Small Businesses/Dunbartonshire Chamber of Commerce The Federation of Small Businesses and Dunbartonshire Chamber of Commerce were provided with details of both stage 1 and stage 2 of the consultation and were asked to promote the details and the survey link to their membership. The Federation of Small Businesses has provided a formal response to the consultation which is provided in Appendix 4. In summary, the Federation of Small Businesses asks that West Dunbartonshire Council rejects or pauses the scheme and asks that the Council work with local businesses to develop a fairer, more proportionate model that safeguards small firms while ensuring the levy delivers meaningful benefits. Loch Lomond & Trossachs National Park engagement session An engagement session was arranged in partnership with the National Park to invite accommodation providers within West Dunbartonshire and local tourism businesses to discuss the draft proposals, gather feedback and identify any issues or concerns that they may have with the proposals. The session was held on 3 October 2025 at the National Park headquarters in Balloch. In total, 8 people from local businesses attended the session. Key Discussions Points from the meeting are provided below:
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Report – Appendix 2 The legislation is unclear as to how costs are applied to venue hire (e.g. for wedding / event packages including accommodation, food and beverage and other charges). Highlighted that many local authorities have developed proposals following Edinburgh’s lead – concern as the nature of the tourism and hospitality sector, and accommodation mix in the National Park is different to that of Edinburgh and other cities. The West Dunbartonshire Council proposal at present does not include any allocation of levy revenue to be retained by businesses to cover additional administrative costs of taking and remitting the levy from staying visitors. VAT rate higher than across Europe. International visitors will want to see an immediate impact from the additional spend on the cost of the Visitor Levy. VAT is a real concern for smaller businesses currently under the VAT threshold. This would have significant consequences to businesses if pushed over the threshold with the levy income being considered as turnover. Seasonality – noted that trading is tough through autumn and winter with many businesses reducing operating days / hours and staffing levels. Concern that a year-round Visitor Levy could deter visitors further from visiting off-season. If some accommodation businesses decide not to open off- season, thousands of visitors will be lost with a knock-on effect to other local businesses, attractions and jobs. Timing – businesses have incurred additional operational costs in recent years along with more regulation. This also comes at a time when there is concern around visitor spending. The introduction of a levy may impact the whole tourism sector and reduce spending while in the destination, such as on attractions and eating out. General comments that some people did not trust West Dunbartonshire Council to spend the money on genuine tourism activity as per guidance document and concerned that the money would be spent on generic council services. How will income be spent? It was noted that a visitor levy should be used in conjunction with a Tourism Strategy – currently there is a gap with the most recent strategy expiring in 2013. Currently a lot of uncertainty regarding detail of implementing a Visitor Levy in Edinburgh – local authorities have the option to delay introducing a Visitor Levy and can pause progress before agreeing to go ahead. The business attendees considered that a pause on any decision to introduce a levy was the most sensible option. Concern that the timing is not good; it would be prudent to see how the introduction in Edinburgh and other areas goes first; and there may be an opportunity that the Scottish Government will review the legislation to amend from a percentage rate to consider a flat-rate.
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Report – Appendix 2 Local Hotels engagement session Local Hotel Managers were invited to an engagement session on 19 September 2025 at Titan Enterprise Business Centre to discuss the visitor levy draft proposals, provide their feedback and raise any questions, issues or concerns that they may have with the draft proposals. 13 local hotel managers were invited to attend the session. In total, 2 hotel managers attended the session with another hotel responding to say they couldn’t attend but were not supportive of a levy scheme being implemented. The hotel managers were not generally supportive of the implementation of a visitor levy in West Dunbartonshire and raised the following issues and concerns: Concern that the implementation of a visitor levy would result in a reduction in hotel bookings and would drive visitors to stay in other local authority areas. Additional costs for the hotels to change their internal IT systems to incorporate the visitor levy. Additional administration costs associated with collecting the levy. Training costs associated with training hotel staff to implement the levy. Concern that they would pay the levy on top of the commission to on-line booking agencies. (booking.com charge 18% commission) Would prefer to have had the option of a flat rate to avoid issues with third party bookings. Additional staff time to explain the levy to potential clients when booking a stay. Concern over starting the levy scheme in July as that is their busiest period. They would prefer the levy to start at a quieter time of year such as January/February if implemented. Advised they may need to look at changing internal processes Concern that as the levy is taxable, they would therefore be asking visitors to pay an additional 6% not 5%. If implemented they feel they should receive a percentage payback to help towards the additional costs associated with implementing the levy as per schemes in other local authority areas. Industry Focus Groups Two industry focus groups were organised during October with invitations issued to B & B’s, short term lets & guest houses registered with Visit Scotland and short term let licence holders through the Licensing team. The Visit Scotland data mainly related to accommodation providers within the Balloch/Alexandria area, so it was decided to organise a second focus group and send an invitation out to all short term let licence holders through the licensing team to increase awareness of the consultation. The first focus group invite was sent to over 40 Visit Scotland accommodation providers for the 7 October 2025 meeting. Few responses were received and no accommodation providers attended on the day. The second focus group invite for 14 October 2025 was sent to the short-term licence holders (approx. 130) through the licensing team. Two accommodation providers attended the second
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Report – Appendix 2 focus group. The comments received from the accommodation providers are provided below: The decision by Argyll and Bute Council not to introduce the visitor levy means that customers have the option of choosing alternative accommodation that will not be charging the 5% + VAT levy. For the sake of an estimated £1.7 million revenue (from which costs will be deducted) do West Dunbartonshire Council elected members think it is right to put local businesses in competition with others nearby that have a price advantage? If the levy is introduced, smaller private operators will reconsider the benefit of continuing with such an enterprise: this follows the Short-Term Let Licence introduction which has brought direct costs (£884.50 per licence) and indirect costs of compliance. Over the past five years, annual revenue for our short term let has increased 4%, whilst direct costs have increased 62% - cleaning and laundry, maintenance, electricity, heating oil, broadband, metered water, etc. In our case, a 5% levy would raise c.£2,850 for West Dunbartonshire Council. The profitability of the short term let business is declining to the point where an added 5% levy may be the final factor in deciding to discontinue: if so, we will no longer spend c.£20,000 in West Dunbartonshire on services (cleaners, laundry, electrician, plumber, gardening, window cleaners, etc). The Council is advised by the Glasgow City Region Intelligence Hub that the visitor levy may raise an estimated £1.7 million. Elected members should question the validity of this information. It relies on research conducted in 2019, before Covid and the considerable increase in living costs since 2022 - two factors that have changed holiday making habits and decisions. The research refers to a paper written in 2019 by an author named Petricek, stating that visitor demand for accommodation in Prague, Berlin and Venice is unaffected by levies - and claiming that such inelasticity can therefore be assumed for West Dunbartonshire Council. Balloch and Clydebank are not comparable with Prague, Venice or Berlin, as visitors can choose to stay elsewhere (for example Argyll and Bute or Ayrshire) and not pay the visitor levy but have the same experience. Furthermore, the paper quoted did not come up on any search of the online library at the University of Glasgow, whilst more contemporary papers from the Journal of Tourism Economics suggest a less clear conclusion. Copied below is an extract from one paper: Despite the progressive introduction of accommodation taxes in many European cities, there is no consensus in the literature as to whether they have positive or negative effects. This may be related to the lack of estimates of the elasticity of visitor demand to accommodation taxes. To fill this gap, we carry out two panel-data regressions using a data set of airline travellers from UK cities to Spanish, French, and Italian destinations between 2012 and 2018. The results from the two-stage least squares regressions indicate that UK international travellers are indeed sensitive to hotel taxes. A levy that is estimated to raise less than 0.3% of the total annual expenditure of West Dunbartonshire Council (£533.9 million in 2024-25) may well lead to a decline in high quality, privately owned and operated holiday accommodation that generates real income for local residents. Larger hotels and
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Report – Appendix 2 accommodation providers (including the possible Flamingo Land) will cope, but with owners and management who are not resident in West Dunbartonshire. There is a real risk that a levy, net of administration and enforcement costs, will be a regressive step for West Dunbartonshire. Economic cycle - the Levy money should benefit the source of the Levy – or - Tourist experience should be reflected to the tourist paying the Levy. Given the geographic boundaries and probability that Levy paying tourists in Gartocharn will go to Stirling or Argyll (or not come) it’s hard to see how the levy spent in West Dunbartonshire Council will provide benefits and form a positive economic cycle. If this is the case, then Operators will lose interest, and a negative economic cycle will evolve. Practicality – business technology is now largely responsible for bookings and transactions are automated on worldwide portals which are not providing the breakdown of data the Levy system will require. We are contracted with two portals with three different economic model contracts, and we don’t know what the selling price is, and we cannot add a levy to a transaction outside our administration. These are global operators, and it makes no sense to ask them to add cost to very efficient worldwide business models – that’s not progress but is retrograding – our business is global except for delivery. Likely outcome – the Levy will create a two-tier system and penalise West Dunbartonshire Council License holding operators – Levy payers will be at a disadvantage of 5% plus VAT to those in Argyll and Stirling or elsewhere such as Ireland. Black market operators based abroad or simply not visible will be stimulated. The compliant levy payer will be penalised, and sales will reduce – a negative economic outcome will evolve. Evidence of Need and Benefit - I am not aware of the need for what a levy is designed to deliver. Has there been a study that says there will be a positive economic outcome from priming by specific investments? If not, then why reduce competitiveness. Lomond Shores went ahead without (arguably against) evidence and has not been a positive investment as far as I know. We don’t have “over tourism” issues quite yet but are close to it in certain areas managed by the National Park at times (but not in West Dunbartonshire). We can trade up in added value, but will the levy do this? The National Park is already very well-funded to provide services in the National Park. I could support a well-presented case for investment possibly on a short-term levy basis if I was convinced it was adding value to our client’s experience and it gives competitive advantage. However, I feel the benefits Captured by the Licensing (predominantly client Safety) are still being paid for, and the sector does not have room for additional costs. An Industry response – Name and Business Provided “I have significant concerns about the quality and scope of the stage two consultation process and operation; businesses on the Short-Term Let register received their first communication from WDC by email on 1st October 2025. Given that the consultation started on 28th July that is quite some time to not communicate the council’s intentions. I have checked with many businesses and, for so many, this was their first
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Report – Appendix 2 awareness of the proposals. In two meetings earlier in the process (in my role as Chair of the LLTNP Destination Group and as a local business who was very aware of the proposals through professional groups) with Gillian Scholes of WDC she said she had been advised that Licensing had previously sent correspondence – this was not the case. Given that only 6.9% of stage one responses were from business owners it is clear that communications have not reached the parties who would be most affected by the introduction of a Visitor Levy. Meetings were set up by WDC in October with various groups, but these were not widely advertised or attended. Given the deadline of 21st October for the stage two consultation and the plan to take a report to committee in November it is hard to believe this has been carried out in a thorough or detailed manner. Indeed, the Council states “the following Draft Scheme has been prepared on the assumption that The Council will be proceeding with proposal to impose a Visitor Levy”. This is not how a consultation should be operated. The outcome and responses received in the stage one consultation indicate a total of 73% of respondents strongly disagreed/disagreed with implementation of a Visitor Levy. There is not a single question in the stage two consultation which acknowledges this. Every question is drafted to indicate a presumption that a visitor levy will be introduced. For the record I think the introduction of a Visitor Levy at this current time of business and cost of living pressure is an absolute disaster. The domestic tourism economy is weak and Scotland is getting a reputation for being a very expensive place to visit. The estimate of a potential £1.7m income in WD does not have a strong foundation at all and certainly doesn’t take account of the adverse economic impact on smaller businesses in introducing this levy. The Draft Scheme is not very comprehensive and therefore probably doesn’t comply with Scottish Government legislation. There is no reference to proposed exemptions (other than those required by statute), no reference to considerations of costs of operating the proposed Levy to accommodation providers. There is no economic impact assessment of the introduction of the proposed scheme. There is no information in the draft scheme about how ‘packaged costs’ are dealt with e.g. accommodation price includes trip to local attraction or includes a meal – these costs shouldn’t be part of the element to be taxed. In many areas, including parts of West Dunbartonshire there is a much quieter period from October to April; perhaps this period should be considered to be free of any levy to help businesses attract more visitors out of season. This would help accommodation businesses but also others including cleaning and laundry companies, visitor attractions and retailers. There is real concern that this is actually a tax on accommodation businesses only and there is very little recognition that many visitors to the area, particularly to the Loch Lomond and Balloch areas are day visitors and would not be making any contribution to the funds used for improving the visitor offer. The proposed figure of 5% also does not come from anything other than ‘that’s what others are doing’ and please bear in mind for customers and visitors this is effectively 6% when VAT is added. It’s not remotely driven by data or research.
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Report – Appendix 2 Many other local authorities have observed the mess which Edinburgh City Council find themselves in with inadequate preparation for introducing a Visitor Levy. A number of councils have chosen not to explore a Visitor Levy at all for various reasons and a good number, at least 6, have put their proposals on hold pending further investigation into the detail of running a scheme and how it will impact on visitor numbers and an already very fragile visitor, tourism and hospitality sector. There is hearsay about possible changes to the legislation to allow councils to consider a flat rate tax. As there are so many elements which are ill thought out and a massive amount of detail which is missing from the draft scheme it is certainly a time to press pause on the introduction of a new burden on small businesses. Visitors paying an additional cost for staying in the area will desire to see improvements which genuinely enhance the tourism sector – this isn’t just an opportunity to cover costs such as grass cutting and litter picking which may be popular amongst some but actually add nothing to the tourism offer. I would request that WDC should not underestimate the significant adverse impact of introducing a Visitor Levy at a time when visitors are questioning every aspect of their discretionary spend ie where to stay, how they spend their money locally, whether they would even travel to an area which has an additional tax (unlike some parts of Scotland and the rest of the UK). Visitors will make choices whether to even come to this area. At the very least I think the prosed Draft Scheme lacks detail, lacks considered thought and would be introduced at a time which proves a disaster for businesses already operating under massive pressure. The number of businesses which have closed since the introduction of the Short Term Let registration is testament to that.” An Industry Response - Accommodation Provider (Anonymous) “We as a business are thoroughly opposed to local taxes which are not consistent throughout the country as they disadvantage parts of the country with higher taxes, making them less competitive/profitable. As an example, WDC were charging approximately twice much as our neighbours in Argyll & Bute for sampling private water supplies. Argyll & Bute have decided not to introduce a visitor levy. The introduction of a visitor levy in WDC would put us at an immediate disadvantage. We have already been hit with the additional cost of applying for a Short Term Let Licence of £884.50 in addition to the cost of complying. If it costs the council £884.50 to administer the licence, it is reasonable to assume it will cost the business owner a similar amount in gathering the information required. Therefore, the true cost to the business is in the region of £1,769 We totally disagree with being asked to pay the tax on our agent’s commission. Looking at the figures for 2024 we would be paying 5% tax on money we do not receive, amounting to £487.52 and a further £98 on the VAT amounting to a total of £585.54 The levy on the income we receive would amount to £2483.04. Therefore, the total tax liability would be £3367.54
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Report – Appendix 2 This is money that is then not available to be spent on property maintenance which benefits local tradesmen, and which will ultimately lead to a poorer visitor experience. Our costs have increased significantly more than income post covid thus eroding our margin and making the business less viable. Loss of businesses in WDC will have a far greater negative impact than the revenue raised by a visitor levy. Administering a visitor levy will also incur WDC in significant costs.” Evening Drop-in sessions During October, two evening drop-in sessions (5.30pm – 7.30pm) were arranged one in Clydebank (Titan Enterprise Business Centre) on 1 October 2025 and one in Dumbarton (St. Augustine’s Episcopal Church) on 8 October 2025. These sessions were promoted through Council social media and through tourism organisations such as Visit Scotland, Loch Lomond & Trossachs National Park and Love Loch Lomond and provided an opportunity in the evenings for accommodation providers or members of the public to drop in and discuss the draft proposals directly with officers. Unfortunately, there was not much interest in either session although this may be due to residents and accommodation providers previously responding through social media channels or they may have attended one of the other engagement sessions or focus groups. Addressing Concerns In addressing the concerns that have been raised it it is important to separate the concerns about the process of the consultation and development of the scheme from the concerns regarding the substance of the underlying proposal. These latter concerns are addressed in the Conclusion, whilst the major concerns regarding process are addressed in the following paragraphs. Process Opaque References: It has been suggested that the references to academic articles quoted were opaque. The article referred to, with the criticism that it was not accessible through Glasgow University online library was utilised because it spoke specifically to price elasticity. Preferring sources for non-academic purposes (e.g. ready availability or inherent bias) should be avoided. There are multiple academic articles which contradict each other and it is important to recognise that broadly comparable may be the best that can be achieved when looking for reference points, and that West Dunbartonshire, like all other places considering a Visitor Levy, will have as many differences as similarities. That does not make references invalid or inappropriate. It simply requires an open and questioning mind. Predetermination: It was suggested that the outcome was pre-determined and consultations should not be undertaken where an end result is identified. This statement identifies a misunderstanding of both the general nature of statutory consultations and in particular the requirements of the Visitor Levy (Scotland) Act
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Report – Appendix 2 2024 and the associated guidance. Generally, statutory consultation procedures will require consultation on a proposal to do a specific thing. It will require an actual proposal with possible consequences identified, in order that the public and particular interest groups can envisage and address those consequences in their responses. Statutory consultations are generally not open ended requests for general thoughts matters. In the case of the Visitor Levy (Scotland) Act 2024 the legislation requires consultation on a proposed scheme. It is thus essential to proceed with a presumption of adoption, or else there would be no consultation exercise. The Council has not only followed the statutory process but has also adopted the approach proposed by Visit Scotland to have an informal first stage of consultation which allows certain issues to be identified and addressed in advance of the formal consultation. Compressed Timescales for Responses: There was some criticism from industry representatives suggesting that there was little time / opportunity to respond. As noted above, through a variety of channels there were many opportunities to respond and far from rushing matters, the Council followed the full required consultation timescale and provided general and specific means to respond. All Short Term let providers were indeed emailed well in advance of the closure of the consultation period and provided with the opportunity to respond and to attend meetings. The meetings were held well out from the end of the consultation period but also, in accordance with best practice, after prospective consultees would have had the opportunity to consider the proposals for some time. The Sum Identified is Unrealistically High and so outcomes are Optimistic: Questions were asked during the consultation regarding how the Glasgow City Region Intelligence Hub estimated the income figure of £1.7 million. Further details from the Intelligence Hub are provided below on how they arrived at that figure. The Glasgow City Region Intelligence Hub (the Hub) utilised academic research, the latest available commercial data, and comparable visitor levies to determine the likely effect of Visitor Levy on West Dunbartonshire’s economy. The methodology implemented by the Hub was reviewed, and supported, by colleagues at the Scottish Government and VisitScotland. The Hub initially estimated the potential impact of a Visitor Levy being implemented based on research conducted by the Fraser of Allander Institute from the University of Strathclyde in 2019. Replicating the Fraser of Allander Institute’s methodology, the Hub then sourced the required inputs to project the potential revenue raised for West Dunbartonshire through the CoStar platform. CoStar is a subscription-based industry-leading platform that provides up-to-date analytics on commercial real estate performance. The platform incorporates accommodation-related data from its subsidiary STR, with STR being a global industry leader for accommodation industry analytics. Individual accommodation analytics cannot be identified due to the signed data-sharing agreement with CoStar. The following inputs were then gathered based on West Dunbartonshire’s latest accommodation market estimates:
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Report – Appendix 2 Average daily hotel room rate: £119.7 Annual number of rooms rented: 183,900 Annual accommodation expenditure: £21.9m These estimates were then supplemented by West Dunbartonshire Council’s own record of short-term let accommodation providers. Comparable levies, such as the Edinburgh Visitor Levy, were consulted to identify other factors that may impact on projected revenues. At this stage the price elasticity of consumers (i.e. how consumers react to price changes) was considered as a potential impact to both the West Dunbartonshire economy and accommodation providers. Previous research from the Fraser of Allander Institute cited multiple case studies across Europe which identified that hotel accommodation demand was relatively price inelastic, and therefore shouldn’t be significantly affected by a relatively small price increase, such as those passed on through the implementation of a Visitor Levy. Updated academic research from papers such as Petricek (2019) also identified the relative price inelasticity of hotel accommodation demand in the cities of Berlin, Warsaw, and Prague. Assuming that accommodation providers would increase their prices to consumers to account for the levy taken (100% pass-through rate), and that consumers are relatively price inelastic to accommodation prices (-0.5 elasticity), the projected revenues for different levies were modelled including the 5% levy which is anticipated to generate approximately £1.7m in revenue While projections will always have an element of uncertainty where rollout of a new income stream is being considered, the Council has been cautious in its estimates and has sought to temper expectations by utilising the estimate at the lower end of the possible range, so as not to overstate the likely beneficial impact of a Levy. If the levy overperforms in coming years there will be the opportunity to revisit, whilst avoiding the corresponding need to increase the levy if the projections are wildly optimistic. Conclusion In conclusion, the feedback from the stage 1 and stage 2 consultations from residents, visitors and accommodation providers generally opposes the implementation of a visitor levy in West Dunbartonshire with a sizeable minority in favour in the Stage 2 online consultation (approx. one third of those expressing an opinion either way). While it will generally be the case that new taxes in any sector will be opposed by that sector unless a direct benefit can be seen as arising for that sector, it has to be recognised that for incremental changes that do not markedly increase burdens on the sector as a whole or individual operators in particular, the opposition is often transcient and based on presumptions which do not come to pass. It is reasonable when considering the impact on the sector to consider other recent changes in the tourist accommodation environment. The introduction of Licenses for
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Report – Appendix 2 20 Short Term lets has been used by some respondents as an example of a recent onerous change for operators and given the introduction a number of safety factors which were not previously enforced, as well as the financial aspects, that was undoubtedly a significant additional burden on operators. The impact of any Visitor Levy is likely to be many times less in terms of the effort required by operators to implement, and also in terms of the costs of implementation. The feedback both in favour and against the proposal requires to be considered in the context of the substantial opportunity that exists for the Council to harness an annual visitor levy income currently estimated to be approximately £1.7 million for purposes identified in the Visitor Levy (Scotland) Act 2024. If implemented at the levels consulted on, a Visitor Levy could contribute approximately £8.5 million income over a five-year period to sustain and support the facilities and services substantially used by visitors for leisure and business purposes within the local area. It is acknowledged that a visitor levy could bring significant benefits to West Dunbartonshire by supporting service provision, infrastructure, tourism events and benefits to the wider visitor economy at a time where Council budgets are under enormous pressure and strain to protect local services to the standards both locals and visitors expect and retain jobs. The impact of visitors on the infrastructure and services provided by Councils is an often hidden burden which a Visitor Levy would look to address. Correspondingly Council is therefore more likely to have the budget available to improve the local tourism offer if visitor levy is implemented. Generally, the feedback from respondents and tourism stakeholder organisations agreed with the use of funds detailed within the draft proposals. Operations and Infrastructure was seen as the most important investment stream, followed by Culture, Heritage and Events, Environmental Protection & Conversation, Tourism Marketing & Management, Climate Change Adaption and Tourism Business & Skills support. During the consultation, accommodation providers frequently raised concerns over additional costs and the resource required to implement a levy. A recommendation has therefore been included that if a levy is implemented, that the addition of a payback to accommodation providers of 1.5% of the collected levy funds be included in the final scheme. This would help cover some of the direct costs which could occur as a result of collecting the levy,. There was also an issue raised around charitable accommodation providers who may only charge a small fee in order to cover operational costs. For clarification, where accommodation services are provided free of charge to the visitors, there would be no ‘chargeable transaction’ and, as such, these stays do not incur a visitor levy. In the case of charitable organisations, it is recommended that the scheme be updated to include a discretionary exemption for charitable accommodation providers where they meet both of the following criteria: Property must be occupied by a charity or a trustee of a charity; and Overnight stays at the property must be wholly or mainly for charitable purpose. This is aligned with the cases where charities may receive
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Report – Appendix 2 21 mandatory relief from Non-Domestic Rates and can be cross-checked with that register. If it is decided to implement a visitor levy, a local guidance document would be produced which would provide accommodation providers with additional information to aid them to understand their responsibilities under the Scheme. This would help to alleviate concerns raised over the administration of the scheme and would include sections on how to calculate the levy, when to charge a levy, exemptions, how to pay the levy to the Council, record retention and enforcement and penalties. It should be noted that there is not currently a local tourism strategy for West Dunbartonshire. If a visitor levy is implemented a new local tourism strategy would need to be developed through consultation with relevant stakeholders. This strategy would assist the visitor levy forum to identify potential uses for the visitor levy funds. It has also been highlighted through the consultation that a few local authorities have decided to pause moving forward with a visitor levy due to strong public opposition from residents, businesses and hospitality groups. These include Shetland, Orkney, Comhairle nan Eilean Siar (Western Isles), South Ayrshire Council and East Ayrshire. Argyll & Bute Council have also recently decided to pause their visitor levy plans to allow the Council to seek clarity from the Scottish Government on possible changes to the visitor levy legislation in relation to a single flat rate or tiered rate instead of a percentage rate as is currently allowed. However, the Scottish Government have advised that they do not currently have any plans to consider changes to the legislation.
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Report – Appendix 2 26 Appendix 2 16 October 2025 Loch Lomond and The Trossachs National Park Authority Response to the West Dunbartonshire Council Visitor Levy Consultation Loch Lomond & The Trossachs National Park Carrochan Carrochan Road Balloch G83 8EG CONTACT: Stuart Mearns, Director of Place 01389 727760 Stuart.mearns@lochlomond-trossachs.org
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Report – Appendix 2 27 Opportunity to comment The National Park Authority (NPA) welcomes the opportunity to advise and input to the development of a potential Visitor Levy scheme by West Dunbartonshire Council (WDC), particularly in respect of the significant tourism development opportunities and management issues which are present in the Council area which overlaps the National Park area. Under the provisions of the Visitor Levy (Scotland) Act 2024, when introducing a Visitor Levy scheme, that under Section 13 (b) a local authority must consult with the National Park Authority in respect of a proposed scheme. Also, under Section 19 (2) in respect of the net proceeds of a Visitor Levy scheme the National Park Authority must be consulted and the scheme must have regard to the National Park Plan as adopted under section 12(7)(a) of the National Parks (Scotland) Act 2000. Through engagement with the four local authorities within the National Park boundary, we are mindful of the how a visitor levy could operate and the impacts on the tourism sector and destination management. Our view is that a consistent approach to implementation would be required to enable clarity for visitors to the area and to support businesses and other key stakeholders who would have a collective interest in how a levy is taken forward across local authority boundaries. A thriving rural economy is essential to the success of our communities. The NPA delivers a fundamental role in encouraging and supporting sustainable tourism development, infrastructure and services that benefits local people and is consistent with net zero and nature commitments, and inspiring people to visit. Background The Loch Lomond and the Trossachs National Park is a significant tourist destination within Scotland attracting over 4.5 million visitors per year, contributing approximately £517m to the local economy and supporting over 7000 jobs within the sector. The Park's tourism appeal is based on its natural beauty, outdoor recreation, and high-quality accommodation and hospitality. Its proximity to Scotland's major urban centres makes it easily accessible, with over 50% of the population living within an hour's drive of the Park boundaries. Due to its popularity and continued incremental growth in visitor numbers—with record levels seen post-pandemic and an anticipated ongoing trend—the National Park is experiencing acute and increasing pressures on both visitor management and infrastructure/services. In relation to these points it should also be noted that the National Park Authority (NPA) undertakes some work that would usually be the responsibility of the Local Authority, notably including being the Outdoor Access Authority, the Planning Authority responsible for the Local Development Plan and having developed Strategic Tourism Infrastructure Plans for parts of the area in partnership with local authorities and local stakeholders. As a key stakeholder and statutory consultee, the NPA is committed to contributing positively to the development of any plans for introducing a visitor levy, should the Council decide to take these powers forward, to ensure positive benefits are realised for the tourism sector. In this context, the NPA would like to make the following observations on the contents of the West Dunbartonshire Council Visitor Levy consultation.
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Report – Appendix 2 28 Use of Visitor Levy Funds The NPA welcomes the overarching aim of the Visitor Levy Scheme to continue to grow the visitor economy and focus on key strengths of Scenery and landscape, history and culture and outdoor pursuits. This fits well with the Parks unique selling points and ambition of increasing Sustainable Tourism. The objectives of West Dunbartonshire’s scheme are to sustain support and develop the following criteria Objective 1: To sustain, support and develop public services, programmes, and infrastructure that provide an enjoyable and safe visitor and resident experience. Objective 2: To sustain, support and develop West Dunbartonshire’s culture, heritage, and events to attract visitors as well as residents. Objective 3: To sustain, support and develop the visitor economy, by fostering innovation in response to environmental and societal challenges, while promoting responsible and sustainable tourism Objective 4: To support tourism marketing and management to promote the West Dunbartonshire area as a visitor destination. Objective 5: To provide assistance to local tourism businesses and improve the skills of the sectors workforce It's good to see these objectives as they align with the National Park Partnership plan’s aims and objectives to increase sustainable tourism however the current Visitor Levy objectives lack reference to the National Park designation, the National Park Partnership Plan 2024-29, and Strategic Tourism Infrastructure Development Plans (STID). There is no breakdown on how proposed monies will be spent. The National Park Authority’s recommendation is that net revenues are distributed appropriately and proportionally to support agreed-upon strategic tourism priorities outlined in the NPPP and related STID’s The National Park comprises collections of high-volume accommodation provision around Balloch, West Loch Lomond and Loch Long, East Loch Lomond, the Trossachs and in the north. Balloch in South Loch Lomond overlaps with West Dunbartonshire Council boundaries and is a popular destination for day visitors as well as overnight tourists. Around hotspots, accommodation providers and customers would rightly expect clear tangible localised enhancements through any levy, should it be introduced - be that public transport provision for visitors and to support staff recruitment and retention; or investment into the ‘destination’ being visited, such as popular loch-side locations, hill paths, long distance routes and visitor facilities. enforce the byelaws and responsible camping behaviours. This consultation response submission aims to ensure that implications for the National Park, including those issues that affect our communities and businesses are highlighted and considered by West Dunbartonshire Council ahead of any decision being made to take forward the Visitor Levy powers set out in the Visitor Levy (Scotland) Act 2024. When developing the levy scheme, there should be clarity on how it will support the NPPP's tourism aims. This includes
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Report – Appendix 2 29 funding infrastructure improvements, sustainable transport, achieving a nature-positive, carbon-neutral destination, and meeting national Net Zero targets. The NPA would welcome the opportunity to continue to be part of the strategic leadership of developing a visitor levy and to be represented on the Visitor Levy Forum should plans to introduce a levy be progressed The NPA is realistic about the monies that could be generated from a visitor levy. Key to the success of a visitor levy will be an uplift in available funds to meet the needs of improving visitor services, enabling new investment opportunities, supporting our communities, and providing additionality to effectively manage and strategically grow the tourism sector sustainably. Local authorities must also determine how the monies collected are distributed to include delivery of tourism related services by other organisations including other public bodies, businesses, community led groups and charities. Many of these organisations already provide high-quality visitor services. A mechanism, such as participatory budgeting or a grant fund scheme, would be advantageous. As businesses and community groups could apply for these funds to support local growth and delivery, this approach also supports the Community Wealth Building model promoted by the Scottish Government. The opportunity for cost-effective, empowered community-led delivery models, enabling and supporting the delivery of projects where they are required the most is not lost. Business Perspective - Through engagement with businesses and having worked closely with the National Park Destination Group (comprising over 35 engaged businesses Park-wide), we have been made aware of the following concerns within the tourism and hospitality sector which may assist in the further development of the scheme. These are relayed without NPA comment: A visitor levy could have a negative effect on the hospitality sector, and in some cases increase the risk of business failure if too high a rate is set. For both international and domestic consumers, high rates could risk Scotland being viewed as a very expensive country to visit. Many organisations carry out pro-bono visitor management work in their local community, representing a significant financial contribution. Consideration should be given for pro-bono and fundraising work to be deducted from the visitor levy costs, as accommodation businesses will simply not be able to afford to do both. Support for the National Park to be allocated sufficient funding to deliver visitor experience improvements. Local Community Development Trusts and organisations such as the National Park Destination Group should also be included within decision making forums that decide of the use of funds. Following recovery from the Covid-19 pandemic, inflationary effects, cost increases geopolitical factors, and a lack of Business Rate relief applied in other parts of the UK, most hospitality businesses are facing a crisis. Businesses perceive that customer pricing is already at its maximum and business profitability is poor and have called for the introduction of a visitor levy to be delayed beyond 2027, until the economy is healthier. Businesses feel that the application of VAT as a charge on a visitor levy, added to a VAT inclusive accommodation cost equates to a triple taxation. The visitor levy adds to an already high rate of
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Report – Appendix 2 30 VAT of 20% which is greater than most other European countries who set a lower rate to support their tourism sector. The above represents a summary of the points that have been raised with the NPA by the businesses who attend our Destination Group meetings. Finally, it is important to carefully consider the potential impacts of a visitor levy as a year-round charge, in particular, a full appreciation of the impact on consumer decision making in comparison to other competing destinations at different times of the year. Unlike other destinations internationally who have sought to manage down visitor numbers by charging a levy, this is not an aim of implementing a visitor levy across all parts of Scotland and account should be taken of the seasonality of the local tourism market and lower occupancy rates at off- peak times of the year. In Conclusion – Tourism in all iterations is vital to the National Park’s economy; it delivers significant benefits and wealth-building to communities through local enterprises, employment and skills development opportunities. It contributes to the Scottish Governments National Strategy of Economic Transformation (NSET) specifically Productive businesses and regions, new market opportunities and a skilled workforce. However, to continue supporting sustainable tourism, we must mitigate negative impacts and strengthen sustainable/green models. We welcome the chance to work with stakeholders on a visitor levy as we believe that a well-considered, strategic approach to tourism development is crucial in delivering a thriving National Park and wider West Dunbartonshire area. We wish to see that the introduction of a levy brings greatest benefits to the tourism sector, supporting thriving communities, destination development and contributing to the strategic aims of Scotland as a world-leader in 21st century tourism, while also meeting Net Zero targets.
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Report – Appendix 2 53 Appendix 5 Views sought on possible introduction of a visitor levy in West Dunbartonshire Published 28 January 2025 Residents, visitors and business owners are being asked to give their views on the possible introduction of a visitor levy in West Dunbartonshire. A consultation is now open giving people the chance to answer nine questions relating to the introduction of a fee which, if introduced, would be charged to visitors who stay in accommodation within the area. Money raised would be used specifically for the benefit of the visitor economy and could include improving facilities and services, supporting local heritage and culture, improving infrastructure and funding tourism events. No decision has yet been made on whether West Dunbartonshire Council will introduce a visitor levy. The information gathered through this consultation, which lasts until the end of February, will be collated and considered by the Council. It will help inform the full consultation which will run later this year and, if a visitor levy is introduced, views shared will contribute to its implementation. Convener of Infrastructure, Regeneration and Economic Development, Councillor David McBride, said: “I would strongly encourage anyone who is interested in whether a visitor levy is introduced in West Dunbartonshire to use this opportunity to have their say. “It is important to be clear that no decision has yet been made on whether this will happen but feedback provided by residents, visitors and those who run businesses here will help to make an informed decision.” Vice Convener of Infrastructure, Regeneration and Economic Development, Councillor Lawrence O’Neill, added: “This questionnaire is the first step in gathering views on the possible introduction of a visitor levy and is a prime opportunity for people to give their thoughts on this. It is a short, easy to answer survey and will help the Council gauge interest and views.” The survey can be accessed at https://www.west-dunbarton.gov.uk/council/public- consultations/west-dunbartonshire-visitor-levy/ and is open until 5pm on Friday, February 28th.
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Report – Appendix 2 54 Published 04 August 2025 Residents, visitors and business owners are being asked to give their views on a draft visitor levy scheme which will later be voted on by councillors. A 12-week consultation has now launched with nine questions focused on the possible introduction of such a programme in West Dunbartonshire. If introduced, money raised would be used specifically for the benefit of the visitor economy under a number of categories including infrastructure, culture and heritage, environmental protection, tourism marketing and business and skills support. Participants are asked to rank the categories in order of preference and also put forward other suggestions for areas of potential investment. If approved, part of the budget could be earmarked for projects which the community would vote on. It is proposed that a 5% fee is added to all overnight stays from July 1st 2027 but is dependent on councillors supporting the move. The consultation, available to access via the Council’s website or in person at the Council offices at 6 Church Street, Dumbarton will run until Tuesday 21st October at 5pm. No decision has yet been made on whether West Dunbartonshire Council will introduce a visitor levy. The information gathered through this consultation will be collated and considered by the Council at a future committee meeting. Convener of Infrastructure, Regeneration and Economic Development, Councillor David McBride, said: “I want to thank the hundreds of people who responded to the initial consultation earlier this year and would encourage them and others to give their views this time around to this more detailed plan. “This part of the consultation focuses on the level of fee which would be paid and how the visitor levy would be operated and ultimately distributed. “It is vital to note that no decision has yet been made which is why it is so important that feedback is given so councillors can make an informed decision.” Vice Convener of Infrastructure, Regeneration and Economic Development, Councillor Lawrence O’Neill, added: “Regardless of whether you are in favour or not of a visitor levy, this is a prime opportunity to give your views as part of this consultation process. “It is a straightforward survey which can be completed in a matter of minutes and so I would urge everyone to have their say.”
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Report – Appendix 2 55 The survey can be accessed at https://www.west-dunbarton.gov.uk/council/public- consultations/visitor-levy-stage-2/