Item 11 - Appendix 3
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 3 Assessment No 1328 Owner brmccolgan Resource Regeneration, Environment and Growth Service Regeneration FirstName Surname Job Title Head Officer Alan Douglas Chief Officer, Regulatory & Regeneration Members Gillian Scholes, Business Support Co-ordinator Brian McColgan, Business Support Officer Ric Rea, Performance & Strategy Officer (Please note: the word 'policy' is used as shorthand for strategy policy function or financial decision) Policy Title Visitor Levy The aim, objective, purpose and intended outcome of policy West Dunbartonshire Council is considering introducing a Visitor Levy. A new law introduced by the Scottish Government – the Visitor Levy (Scotland) Act 2024 has provided councils in Scotland with the option to introduce a visitor levy in their local area. If West Dunbartonshire introduces a visitor levy, the money raised must be used to develop, support, and sustain facilities and services which are substantially used by visitors for leisure and business purposes. The Levy will be set at a percentage rate of 5% across West Dunbartonshire. A number of groups do not fall within the scope of the Act and are therefore not liable to pay a visitor levy charge. These groups, with the exception of those in receipt of specified disability payments, are not considered visitors to an area for business or leisure purposes, and are therefore not liable to pay a levy charge. These groups are: a. Those who are using overnight accommodation as their only or primary residence, which could be due to: i. being homeless or at risk of homelessness ii. very poor housing conditions (such as overcrowding, serious damp or disrepair) iii. experiencing domestic abuse or other forms of violence iv. someone’s residence being unfit for habitation v. someone being an asylum seeker or refugee 2. In addition, the visitor levy does not apply to: a. someone staying on a dedicated gypsy/traveller site run by a local authority or a registered social landlord b. those in receipt of the following specified disability benefits, payments, or allowances: i. Disability Living Allowance ii. Disability Assistance iii. Attendance Allowance iv. Pension Age Disability Benefit v. Personal Independence Payment Service/Partners/Stakeholders/service users involved in the development and/or implementation of policy. ITEM 11 - APPENDIX 3
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Report Appendix 3 Legal Licensing Finance Loch Lomond and Trossachs National Park Love Loch Lomond Federation of Small Businesses Visit Scotland Visitor accommodation providers in West Dunbartonshire Does the proposals involve the procurement of any goods or services? No If yes please confirm that you have contacted our procurement services to discuss your requirements. No SCREENING You must indicate if there is any relevance to the four areas Duty to eliminate discrimination (E), advance equal opportunities (A) or foster good relations (F) Yes Relevance to Human Rights (HR) Yes Relevance to Health Impacts (H) Yes Relevance to Social Economic Impacts (SE) Yes Who will be affected by this policy? Visitors to West Dunbartonshire. Residents of West Dunbartonshire who pay for overnight accommodation within the area. Accommodation Providers in West Dunbartonshire. Who will be/has been involved in the consultation process? An initial online consultation exercise was carried out over a 6-week period, from 20 January to 28 February 2025. In total, there were 563 responses to the survey. The majority of the people that completed the survey were residents of West Dunbartonshire (86.5%). Only 6.7% of respondents identified as visitors to the area along with 15.3% of respondents stating that they had friends or relatives that live within the West Dunbartonshire area. Business owners only equated to 6.9% of respondents. In terms of sex 49.08% of respondents described their sex as female, 35.58% as male, 1.23% as intersex and 1.23% as in another way. 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. The main comments provided by respondents to explain why they disagreed with the implementation of a visitor levy, included not feeling that the local area had enough of a tourism offering to warrant charging a levy and also that they felt a visitor levy would put visitors off from staying in the local area. The stage 1 survey asked respondents what they would like to see the levy income spent on, keeping the area clean and tidy came out top with 56% voting for that option closely followed by transport services and infrastructure with 41%. Council parks and greenspace were also highly rated with 38% and Culture, Heritage & Events were also viewed as important with 25% of the result. (respondents could tick more than one box). Other responses included suggestions such as using the income to improve leisure centres, improve the congestion on A82, fixing woodland paths and creating tourism attractions. Following the stage 1 survey, a draft visitor levy scheme was developed and feedback on the draft scheme was sought through stage 2 of the consultation. The draft scheme proposals were available through the Council website and have been shared with relevant stakeholders.
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Report Appendix 3 The stage 2 formal consultation ran from 28 July to 21 October 2025. The consultation consisted of a press release, social media posts, an on-line survey, hotel engagement session, National Park engagement session, industry focus group, stakeholder meetings and public drop-in sessions. In total, there were 214 people that responded to the Stage 2 survey. Results from this survey included: In terms of sex 49.53% described their sex as female, 36.45% as male, 0.93% as intersex and 0.93% as in another way. The majority of the people that completed the survey were residents of West Dunbartonshire (79.4%). Business owners equated to 13% of respondents and only 7.5% of respondents identified as visitors to the area. People were asked overall, on a scale of 1 to 5, where 1 is strongly agree and 5 is strongly disagree, how they would rate their general support for introducing a Visitor Levy in West Dunbartonshire. A total of 207 people answered this question, 60.7% of people strongly disagreed/disagreed with the introduction of a visitor levy with 30.8% of people strongly agreeing/agreeing and 5.1% neither agreed nor disagreed. The respondents to the survey were asked to rate the proposed investment streams in order of importance. The respondents rated Operations and Infrastructure 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. A Visitor Levy Consultation Findings Report has been completed which provides more detail on the results of the stage 1 and stage 2 formal consultation.
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Report Appendix 3 Please outline any particular need/barriers which equality groups may have in relation to this policy list evidence you are using to support this and whether there is any negative impact on particular groups. Specific group to consider Needs Evidence Impact Age Need to assess for any differential impacts. The Visitor levy will apply regardless of age. In relation to younger people specifically, the 2020 Scottish Household Survey noted that younger age groups had notably higher rates of attending a cultural event or visiting places of culture than older age groups. The Scottish Government’s Visitor Levy Equality Impact work found that “Children and young people stakeholder organisations (including the Scottish Youth Parliament, and YoungScot) were invited to respond to the National Consultation, and were engaged bilaterally to submit any concerns on the policy for children and young people. No concerns were raised from stakeholder organisations.” No significant impacts identified. Disability Need to assess for any differential impacts Adapted accommodation. Medical treatment Disabled people may face higher accommodation costs if requiring e.g. adapted accommodation, and hence Visitor Levy cost would be higher Any negative impact mit- igated/removed by virtue of Section 14 of the Visitor Levy (Scotland) Act, which exempts all individuals in receipt of the following UK disability benefits, payments, or allowances from paying the levy: • Disability Living Allow- ance • Disability Assistance • Attendance Allowance • Pension Age Disability Benefit • Personal Independ- ence Payment Individuals in these cat- egories will need to pay the levy and request reimbursement from the Council. Reimbursement will be applied for online, submitting receipts for their overnight stay, rel- evant evidence (as de- tailed on the Council’s website) of their exemp- tion/exclusion and bank details. The refund sys- tem will be designed to be fully accessible for all. Communication
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Report Appendix 3 around this area will be developed to assist with the refund process and the process will aim to pro-cess refunds timeously. In relation to potential medical treatments the potential negative impact of the Visitor Levy is mit- igated by the NHS which allows accommodation costs incurred in these situations to be re- claimed. Gender Reassign Consideration has been given for those who require medical treatment as part of a person's gender reassignment process. No evidence of any impacts specific to this protected characteristic, with the possible exception of stays required for medical treatment. The potential negative impact of the Visitor Levy is mitigated by the NHS which allows accommodation costs incurred in these situations to be reclaimed. Marriage & Civil Partnership Need to assess for any differential impacts. No evidence of any impacts specific to this protected characteristic. No significant impacts identified. Pregnancy & Maternity Need to assess for any differential impacts. If visits are for medical treatment, people from this group would be claim accommodation costs from the NHS The potential negative impact of the Visitor Levy is mitigated by the NHS which allows accommodation costs incurred in these situations to be reclaimed. Race Gypsy/travellers Refugees Asylum seekers. The Visitor Levy will apply to all regardless of Race. There is limited, if any, data available regarding racial characteristics of visitors to Scotland. Data collection tends to be around country of origin rather than race, as reported by VisitScotland. However, some racial groups have been identified who may be negatively impacted by the introduction of a Visitor Levy: Gypsy/travellers may require overnight accommodation Refugees may require overnight accommodation. Asylum seekers may require overnight accommodation. Potential negative impact depending on the type of site where members of the Gypsy/Traveller communities choose to reside. This will be mitigated as members of the Gypsy/Traveller communities staying on dedicated sites will be exempt from paying the Visitor Levy. Refugees are exempt from the Visitor Levy. Asylum seekers are exempt from the Visitor Levy.
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Report Appendix 3 Religion and Belief Need to assess for any differential impacts. No evidence of any significant impacts specific to this protected characteristic. No significant impacts identified. Sex Need to assess for any differential impacts. The Visitor Levy provisions do not make any distinction based on sex. However, Hospitality and Tourism is an important sector for the employment of women. The sector has one of the highest numbers of female workers, who make up 54.2% of the workforce. Because of this it is also a popular sector for women to set up their own business. The Federation of Small Business (FSB) has stated in its research that 31% of small businesses are owned by women, rising to 41% of small businesses in the hospitality and tourism sector. No significant impacts identified. Mitigations for businesses in general are identified below. Sexual Orientation Need to assess for any differential impacts. No evidence of any impacts specific to this protected characteristic. No significant impacts identified. Human Rights The Council is a duty bearer in terms of the European Convention of Human Rights/Human Rights Act and under the terms of United Nations Convention on the Rights of the Child incorporation into Scottish Law People visiting those in prison or attending court proceedings may be negatively affected, as families affected by imprisonment often face financial stresses. Mitigation: Funding is available (in the UK and in Scotland) for those visiting people in prison, which means that those with the most need will not be negatively affected by the implementation of a Visitor Levy. Health Medical Treatments Some people may require accommodation when attending for medical procedures, or if they are a parent, primary carer or sibling of a young inpatient under the age of 18 receiving hospital care. The potential negative impact of the Visitor Levy is mitigated by the NHS which allows accommodation costs incurred in these situations to be reclaimed. Social & Economic Impact Fairer Scotland Duty Impact on Businesses The Consumer Duty In relation to the Fairer Scotland Duty we have had regard to reducing "inequalities of outcome" potentially caused by a Visitor Levy. The exemptions introduced by the legislation around visitors in receipt of certain welfare benefits (see above) will apply in West Dunbartonshire. The Visitor Levy will be set at a percentage rate, rather than a flat rate. This will mean it is proportionate to the type and price of accommodation used. Therefore visitors choosing to stay in cheaper Potential negative impacts: • Increased administrative burden and higher costs • Potential requirement to register for VAT • Potential loss of business due to decline in visitor numbers. • Potential for lower spend by visitors to the area. • Potential that smaller providers may opt to cease providing due to additional burdens
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Report Appendix 3 accommodation will be charged the Visitor Levy proportionately. This is highlighted by the Scottish Government in their own Impact Assessment. In relation to the potential impact of the Visitor Levy on businesses, there are 205 businesses in West Dunbartonshire which are categorised as “Accommodation and food services”, Scottish Government Businesses in Scotland 2024. There may be both negative and positive impacts for businesses involved in the visitor/tourism sector in West Dunbartonshire. The Scottish Government’s Business and Regulatory Impact Assessment (BRIA) of the Visitor Levy Bill considered issues around: • Costs to businesses • How the levy should be collected • Possible VAT implications for businesses. The current threshold for VAT registration is total taxable turnover of £90,000. It is possible that the Visitor Levy could increase taxable turnover for some businesses. • How revenue generated by the levy could be spent in such ways as to benefit tourism businesses 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 (VL) 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 noted that “Previous research from the Fraser of AlIander Institute cited multiple case studies across Europe which identified that hotel accommodation demand was created by the Visitor levy. • Potential disadvantage created by a non- universally introduced Visitor Levy, i.e. visitors may choose to visit an area which does not have a Visitor Levy rather than an area which does. It is thought that these potential negative impacts would be mitigated by some features of the Visitor Levy, e.g. • The Scottish Government BRIA found that “Evidence from cities that have introduced these types of taxes recently show that generally growth in visitor numbers has continued after the introduction of these taxes. • The introduction of a national portal for managing and administering the Levy, and training in its use will be provided to businesses • The payment of a proportion of Levy revenue back to businesses • Improvements to visitor related infrastructure resulting from the Visitor Levy and an increase in visitor numbers as a result • Some revenue from the Visitor Levy may be spent on additional events in West Dunbartonshire which will attract more visitors • Other types of business in the area will benefit from increased visitor numbers • A local Visitor Levy guidance document will be developed to assist businesses with the implementation of the Visitor Levy
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Report Appendix 3 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.” We have also carried out our own engagement with businesses in the form of focus groups and drop-in sessions. Issues raised echoed those identified in the Scottish Government BRIA. • We will offer any local businesses who are impacted by the introduction of the Levy advice and assistance through our Business support and Business Gateway services. • An element of participatory budgeting may be introduced funded by the revenues generated by the Visitor Levy. This would empower residents of West Dunbartonshire who are potentially negatively impacted by the introduction of a Visitor Levy It is thought that the potential positive impacts listed above may mitigate any potential “harm” to businesses resulting from the introduction of a Visitor Levy. Cross Cutting The Consumer Duty The consumer duty aims to put consumer interests at the heart of strategic decision-making across the public sector to deliver better policy outcomes for Scotland. This approach should result in better quality services and outcomes for consumers as users of public services. When they are making decisions of a strategic nature through the exercise of their functions they must have regard to: • the impact of those decisions on consumers in Scotland • the desirability of reducing harm to consumers in Scotland The introduction of a Visitor Levy may represent a potential “harm” to consumers. All members of all equality groups are potential consumers, as are the population in general and small businesses. 185 of the 205 registered businesses in the “Accommodation and food services sector” in West Dunbartonshire are small businesses. We have had regard to the principles of the Consumer Duty in relation the Visitor Levy, including by engaging with the consumers potentially affected by the Visitor Levy, both the businesses who will have to collect the Levy and individuals who will have to pay the Levy. This has been done through survey and face to face engagement. In relation to the Consumer Duty, some of the positive impacts of the Visitor Levy will mitigate negative impacts (see above). The consumer principles are considered below: Access Can people get the goods or services they need or want? – The Visitor Levy will not affect access to accommodation. Choice Is there any meaningful choice? – Consumers will still have a range of accommodation types to choose from. Safety Are consumers adequately protected from risks of harm? – There are no impacts around physical or mental harm arising from the Visitor Levy. Information Is it accessible, accurate and useful? – The introduction of the Visitor Levy will be publicized widely and full information made
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Report Appendix 3 available to all consumers. Fairness Are all consumers treated equally, honestly and justly? – With the exception of statutory exemptions, see above, the Visitor Levy will apply to all consumers. Representation Do consumers have a meaningful role in shaping how goods and services are designed and provided? – We have engaged with consumers through survey work and focus groups to inform the development of the Visitor Levy. Redress If things go wrong, is there an accessible and simple way to put them right? – Collection of the Visitor Levy will be managed through a national online portal and managed locally be Council staff. Detailed guidance and procedures and processes will be developed.
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Report Appendix 3 Actions
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Report Appendix 3 Policy has a negative impact on an equality group,but is still to be implemented, please provide justification for this. Measures to mitigate negative impacts highlighted above have been incorporated in the legislation and will apply in West Dunbartonshire. Other positive aspects of the Visitor Levy also highlighted above will also mitigate any negative impacts. Will the impact of the policy be monitored and reported on an ongoing basis? Yes. A Visitor Levy Forum will be established to monitor the impacts of the Levy. The composition of the Forum will be decided at a later date if the Council approves the introduction of the Visitor Levy. Q7 What is you recommendation for this policy? Introduce Please provide a meaningful summary of how you have reached the recommendation EIA 1328: The Visitor Levy will apply to all who pay for accommodation in West Dunbartonshire, hence there will be a potential negative financial impact on all who do so, including those with protected characteristics. In some cases, i.e. Disability and Race, the legislation provides mitigation for this. In other cases, i.e. health related situations, there are existing schemes which will mitigate the negative impact. Additionally, the Council has the power to make specific local exemptions. In other cases the general positive impacts deriving from the revenues generated by a Visitor Levy, e.g. improved infrastructure and services, will help mitigate any negative impacts and will benefit both visitors and residents of the area. In relation to tourism and other businesses in the area, it is acknowledged that there may be negative impacts for businesses. These could include additional administrative burden for processing the Visitor Levy and potentially being required to register for VAT if turnover increases due to the Visitor Levy. It is also possible that that visitor numbers could fall as a result of the Visitor Levy. However, there may also be benefits for businesses from the Visitor Levy, including improvements to the tourism infrastructure and offer in West Dunbartonshire and higher visitor numbers resulting from this. Feedback Respondents to the stage 2 survey were asked to rate the proposed investment streams for revenues generated by a Visitor Levy in order of importance. The respondents rated Operations and Infrastructure 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. Any investments made will be subject to further consultation and input from the Visitor Levy Forum which will be comprised of a wide range of stakeholders. The Council will also develop a specific Tourism strategy to complement the Visitor Levy and take a strategic approach to the further development of the Tourism sector. This will reinforce the Council's general Economic Development Strategy which recognises the importance of sustainable tourism for the area as a contributor to economic growth. Conclusion While it is recognised that the feedback received from stage 1 and stage 2 consultations has not been generally supportive of the implementation of a visitor levy, this will need to be considered along with the substantial opportunity that exists for the Council to receive an annual visitor levy income estimated to be approximately £1.7 million, which if implemented 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.
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Report Appendix 3