Democracy Spraffa

Community Wealth Building Bill and Cruise Ship Levy Bill Consultatons: Argyll and Bute Council Officer Responses

Argyll and Bute Council · 19 June 2025
Back to Environment, Development and Infrastructure Committee — 19 June 2025 and its agenda

Text extracted from the council's PDF. Layout and reading order may differ from the original.

Original council PDF · Download plain text

Page 1

ARGYLL AND BUTE COUNCIL  ENVIRONMENT, DEVELOPMENT AND
INFRASTRUCTURE 
DEVELOPMENT & ECONOMIC GROWTH                             19TH JUNE 2025
COMMUNITY WEALTH BUILDING BILL AND CRUISE SHIP LEVY BILL
CONSULTATONS: ARGYLL AND BUTE COUNCIL OFFICER RESPONSES 
1.0 INTRODUCTION 
1.1 The purpose of this paper is to inform the Environment, Development and
Infrastructure (EDI) Committee with the Argyll and Bute Council officer responses
to the recent ‘call for views’ consultations for the proposed Community Wealth
Building (Scotland) Bill and the Cruise Ship Levy (Scotland) Bill currently
progressing through the Scottish Parliament. 
1.2 The detailed Argyll and Bute officer response to each of the consultation questions
is outlined for the Community Wealth Building Bill and the Cruise Ship Levy Bill in
Appendices 1 and 2 respectively. 
1.3 The submission deadline for the Community Wealth Building Bill consultation was
Monday, 26th May (updated from Friday, 23rd May) and Friday, 30th May for the
Cruise Ship Levy Bill. Therefore, this paper has been prepared for the EDI
Committee on 19th June 2025 to enable members to homologate the submitted
responses. 
1.4 The Argyll and Bute officer response to the Community Wealth Building Bill has
contributed to a collective response from the Scottish Local Authorities Economic
Development (SLAED) Executive. It is proposed that a letter on some of the
overarching issues for a Cruise Ship Levy (Scotland) Bill (see paragraph 3.10)
noted by the seven local authorities located across the Highlands and Islands who
are part of a Highlands and Islands Regional Economic Partnership Visitor
Levy/Cruise Ship Levy Short Life Working Group will be send to Shona Robison,
MSP, Cabinet Secretary for Finance and Local Government. 
2.0 RECOMMENDATIONS 
2.1 Members of EDI are asked to: 
• Note the content of this report. 
• Note the Argyll and Bute Council officer responses to the questions in both
consultations in Appendix 1 and Appendix 2. As the deadline for submission to
the Scottish Government was 26th May and 30th May respectively, officers
submitted responses aligned to the requested timetable. The responses were
considered and commentary provided for inclusion in the submissions by
members of the Executive Leadership Team. In addition. the Argyll Islands
Sounding Board considered the response to the Cruise Ship Levy (Scotland) Bill.

Page 2

• Agree to homologate the officer responses. As the consultations have closed
officers suggest that any additional substantive comments from members of this
committee could be submitted in writing to Tom Arthur, MSP, Minister for
Employment and Investment (where Community Wealth Building is included in
his portfolio) and on the Cruise Ship Levy to Shona Robison, MSP and Cabinet
Secretary for Finance and Local Government. 
3.0 DETAIL
Community Wealth Building (Scotland) Bill
3.1 The Community Wealth Building (Scotland) Bill aims to ensure that local authorities
and other parts of the public sector implement community wealth building across
Scotland. 
3.2 Community Wealth Building is a practical approach to local economic development
that supports the delivery of a wellbeing economy. It uses the economic power of
‘anchor’ institutions to try and stimulate and retain economic activity within a local
economy. Anchor institutions are public, private or third sector bodies that have a
large enough presence in a local economy to change economic outcomes. The Bill,
however, only places duties on public sector organisations. 
3.3 There are five ‘pillars’ to Community Wealth Building as follows:
• Spending: maximising community benefits through procurement and
commissioning, developing good enterprises, fair work and shorter supply
chains.
• Workforce: increasing Fair Work and developing local labour markets that
support wellbeing of communities. 
• Land and Property: growing social, ecological, financial, and economic value
that local communities gain from land and property assets. 
• Inclusive Ownership: developing more local and social enterprises which
generate community wealth, including social enterprises, employee-owned
firms, and cooperatives.
• Finance: ensuring that flows of investment and financial institutions work for
local people, communities, and businesses. 
3.4 Much of this activity is already happening across Argyll and Bute - and with
increasing prevalence. Local authorities currently have permissive powers over
economic development. This means that they can undertake economic
development activities, such as funding business support services. The Bill would
place statutory duties on local authorities in relation to how they approach
economic development. 
3.5 There is concern around whether the duties are proportionate to the current staff
capacity and resource levels of public sector organisations. Like other local
authority areas, Argyll and Bute is already under considerable financial and staffing
pressures, so without sufficient funding and support (particularly the required staff
costs of circa £70k), the new duties are at risk of becoming a tick-box exercise
rather than delivering meaningful change.

Page 3

3.6 Success of the Bill will depend on whether the Scottish Government provides
adequate financial and practical support alongside the legislation. In particular,
direction is required on how existing activities can be aligned to the CWB pillars. 
3.7 Appendix 1 outlines the Argyll and Bute Council officer responses to a variety of
questions on the proposed Community Wealth Building (Scotland Bill). 
Cruise Ship Levy (Scotland) Bill 
3.8 The Scottish Government is bringing forward legislation (Bill) to give local
authorities new powers to introduce a Cruise Ship Levy. This aligns with the Verity
House Agreement, July 2023, part of the New Deal with Local Government, which
includes a commitment to provide greater flexibility for local authorities over
financial arrangements. This commitment includes consideration of further revenue
raising powers for local government. 
3.9 Appendix 2 outlines the Argyll and Bute Council officer responses to a variety of
questions. 
3.10 A summary of issues, not all captured due to the questions posed, are as follows: 
• A Cruise Ship Levy should be based on an overarching principle of simplicity
both in terms of the process surrounding the introduction of powers and design. 
• Levy powers will provide local authorities with key additional resources for
investment in vital local services. This could improve tourism offer for Argyll and
Bute. 
• Local flexibility should be a key element of a Cruise Ship Levy. There should be
no national direction on the rates set by local authorities and the use of revenue
should be up to the discretion of local authorities. It is noted that guidance could
potentially encourage regional collaboration to reflect the unique nature of the
Cruise Ship Levy market throughout the process of developing levy schemes,
but this will need to be articulated clearly on how this would work in practice 
• The administrative burden of a Cruise Ship Levy should be minimised as much
as possible. This will require careful consideration on whether to charge the levy
on a per passenger basis (more straightforward for administrative purposes) or
based on the number of passengers who disembark at that destination. 
• The powers contained in any legislation should be expanded to allow local
authorities with islands to apply a Cruise Ship Levy at the point of entry. This
could also apply to motorhomes and could offer an alternative to a Visitor Levy
for island communities being charged solely for overnight accommodation, as
under the current Visitor Levy (Scotland) Act 2024. 
• The consideration of environmental impacts of cruise ships should not be
considered in this legislation. This would over complicate the policy rationale

Page 4

behind a Cruise Ship Levy at the outset. Environmental levies on all vessels
calling into harbours are already applied in many areas. 
4.0 CONCLUSION 
4.1  The detailed Argyll and Bute officer response to each of the consultation questions
is outlined for the Community Wealth Building Bill and the Cruise Ship Levy Bill in
Appendices 1 and 2 respectively. 
4.2 It is anticipated that there will be ongoing discussions on these Bills, with updates
provided to members of the EDI Committee as appropriate, as both pieces of
legislation progress through the Scottish Parliament. 
5.0 IMPLICATIONS 
5.1 Policy – Community Wealth Building (Scotland) Bill and the Cruise Ship Levy
(Scotland) Bill currently progressing through the Scottish Parliament. 
5.2 Financial – Argyll and Bute is already under considerable financial and staffing
pressures, so new legislative duties for local authorities should be accompanied by
sufficient funding and support. 
5.3 Legal – none until the Bills have been passed and become an Act of Parliament. 
5.4 HR – staffing required to support delivery of additional statutory policy requirements
associated with the Community Wealth Building Bill (as per the Financial
Memorandum) and to consider the practicalities of introducing a Cruise Ship Levy
for Argyll and Bute. 
5.5 Customer Service – none. 
5.6 Risk - limited staff capacity to implement the required Community Wealth Building
activity including the preparation of an Action Plan and the consideration and
necessary consultation activity for a Cruise Ship Levy. 
5.7 Climate Change – none. 
5.8 Fairer Scotland Duty - the Fairer Scotland Duty, Part 1 of the Equality Act 2010,
came into force in April 2018. The duty places a legal responsibility on particular
public bodies in Scotland, such as Argyll and Bute Council, to pay due regard to
(actively consider) how they can reduce inequalities of outcome, caused by socio-
economic disadvantage, when making strategic decisions and how this has been
implemented. 
5.9 Equalities (protected characteristics) - all activities will comply with all Equal
Opportunities policies and obligations. 
5.10 Consumer Duty - all activities will comply with the council’s Consumer Duty.

Page 5

5.11 Island Communities - all policy activity will include islands. Specific consideration to
be given to a point of entry visitor levy for islands. 
5.12 Children’s Rights and Wellbeing – none. 
Kirsty Flanagan, Executive Director responsible for Development and Economic
Growth 
Policy Lead for Business Development, Councillor Math Campbell-Sturgess
Policy Lead for Community Wealth Building, Councillor Mark Irvine 
28th May 2025 
For further information contact: 
Fergus Murray, Head of Development and Economic Growth
Tel: 01546 604293 and e-mail: fergus.murray@argyll-bute.gov.uk 
Ishabel Bremner, Economic Growth Manager
Tel: 01546 604375 and e-mail: ishabel.bremner@argyll-bute.gov.uk 
APPENDICES 
Appendix 1: Argyll and Bute Officer Response to the Community Wealth Building
(Scotland) Bill consultation.
Appendix 2: Argyll and Bute Officer Response to the Cruise Ship Levy Consultation.

Page 6

Appendix 1: Argyll and Bute Officer Response to the Community Wealth Building
(Scotland) Bill consultation 
Question page 1
1 The Scottish Government’s objective is to ensure consistent implementation of
Community Wealth Building across Scotland.
(a) Do you think the proposed Bill will achieve this objective? 
The CWB Bill is a constructive step to formally recognise CWB as a strategic approach to
economic development, particularly as this is not currently a statutory function for local
authorities. However, success will depend on how it is implemented – particularly in relation
to resources, clarity of guidance, and capacity-building. It provides a national framework,
while also allowing for local flexibility, as well as fostering collaboration and partnership
working between anchor institutions to address local needs, priorities and opportunities.
However, the Bill lacks detail, particularly around how public bodies will be supported to
meet the obligations, move beyond high-level commitment to achieve meaningful change. 
It is suggested that the Bill is a steppingstone, and that robust legislation is needed to embed
the aspirations of fairness, equity, and sustainability. It will be important to ensure that the
guidance helps local authorities to recognise how existing activities already contribute to the
CWB agenda, and what changes could be made to redirect existing efforts and avoid the
perception that the CWB requirements are an additional burden. 
Without sufficient resourcing, such as the financial support to fund a CWB team leader post
(including on-costs), as outlined in the Financial Memorandum, meeting the requirements of
the Bill could become a tick-box exercise, rather than a catalyst for genuine local economic
transformation. 
(b) Does the Scottish Government need to change the law to achieve this objective? 
Yes. 
Please explain your answer. 
Changing the law is necessary to ensure consistent, accountable, and meaningful
implementation of CWB across Scotland. Introducing a statutory duty would formalise CWB
as a core function for local authorities, raising its profile and strengthening accountability. It
would also ensure that all local authorities are required to embed CWB principles in their
operations. While the CWB Bill frames CWB as an economic development approach, the
approach has significant impacts on and interdependencies with a wide range of policy areas
for local authorities and partners, including procurement, fair work, land use, housing, and
community empowerment. Legislation would provide the legal basis to support a more
inclusive, community-focused approach, supporting prioritisation of community benefit and
local impact in policy and decision-making. 
However, legislation alone is not sufficient. To ensure successful implementation, it must be
underpinned by clear and practical guidance, adequate financial revenue support to fund
staffing costs, capacity-building support, and robust monitoring and evaluation mechanisms.
Complementary legislative changes – particularly in procurement – are also needed to

Page 7

empower public bodies to support local employment, investment, and supply chains. A
clearer timeline for wider reforms, such as updates to the Procurement Reform (Scotland)
Act 2014, would provide valuable context for local authorities planning to prepare CWB
plans. 
(c) Are there other ways in which the Scottish Government could achieve this
objective? Please explain your answer 
In addition to legislation, consistent implementation will need to be underpinned by a range
of complementary measures to ensure that all local authorities and anchor institutions are
equipped to deliver effectively. 
The need for targeted local authority funding, including dedicated financial resources (such
as staffing costs) to support CWB activity would enable local authorities to engage more fully
in delivering CWB priorities, particularly in areas such as Argyll and Bute with stretched
budgets and a vast dispersed geography of fragile rural/island economies facing complex
local economic challenges. Local authority funding could be targeted at projects that promote
local employment, build local business bases, and enhance the resilience of local
economies. 
In addition to funding, there is a need for clear national guidance and standards. Robust
frameworks and practical toolkits would provide direction and consistency across public
bodies. These materials would support a shared understanding of what effective CWB
practice looks like and support consistency across areas while still allowing for local
variability. Clarity around expectations would help ensure that CWB becomes embedded in
everyday decision-making. A national monitoring and reporting framework, underpinned by
consistent measures and indicators, would help to promote transparency, track progress,
and assess the local and collective impact of CWB. 
Embedding CWB within existing policy and funding structures would support consistent and
effective implementation. Integrating CWB principles into procurement legislation, economic
development strategies, growth deals, and other mechanisms would help mainstream the
approach and avoid duplication or fragmentation. 
Many anchor organisations at the local Argyll and Bute level will require additional support to
build the internal skills, leadership capacity, and cross-sector collaboration needed to
progress CWB. Targeted training and shared learning opportunities could help address gaps
and support capacity building. As well as ensuring internal buy-in, public engagement in the
development of CWB plans is essential to ensure that community voices, needs and
aspirations are also reflected. 
There is significant value in existing networks, particularly the CWB Practitioners’ Network,
which play a vital role in knowledge exchange and peer to peer support, as well as fostering
collaboration and building understanding of CWB principles. Maintaining and expanding
these networks would enable local authorities and partners to exchange examples of good
practice, explore challenges, and co-develop solutions.

Page 8

2 The Bill would place extra duties on some public sector organisations. Are these
duties proportionate? Do these organisations have the capacity and resources to
meet the duties placed on them? 
The duties are broadly positive and aligned with the ambition of embedding CWB principles
across Scotland. However, there is concern around whether the duties are proportionate to
the current staff capacity and resource levels of public sector organisations. Like other local
authority areas, Argyll and Bute is already under considerable financial and staffing
pressures, so without sufficient funding and support (particularly the required staff costs of
circa £70k), the new duties are at risk of becoming a tick-box exercise rather than delivering
meaningful change. 
Success of the Bill will depend on whether the Scottish Government provides adequate
financial and practical support alongside the legislation. In particular, direction is required on
how existing activities can be aligned to the CWB pillars. 
3 Do you agree with the list of relevant public bodies proposed in the Bill? If not, how
should these be changed? 
There is broad agreement with the proposed list of relevant public bodies in that it includes
key organisations that significantly shape local and regional economies. However, some
additions should be made to better reflect how CWB operates in practice and to increase the
potential impacts of partnership working for example local housing bodies and local
development trusts should be included as important anchor organisations for Argyll and
Bute. 
Formal recognition should also be given to the third sector, especially through the inclusion
of Third Sector Interfaces or social enterprise networks, as a key player in delivering CWB
activity at the community level. 
The current list provides a useful starting point but requires tailoring. It is also important to
note the vital roles of the private sector and community stakeholders as these will strengthen
implementation potential and better reflect the collaborative, placed-based nature of CWB.
Rather than creating new, standalone CWB partnerships, it is suggested that duties could be
aligned with existing governance structures such as Community Planning Partnerships to
avoid duplication and enhance efficiency.

Page 9

Question page 2
1 Do you agree with the list of specified public bodies proposed in the Bill? If not, how
should these be changed? 
It is currently unclear how agencies have been classified as either ‘specified’ or ‘relevant’
public bodies, and these categories may be too narrow to deliver maximum economic
benefit. For example, Forestry and Land Scotland is an agency of the Scottish Government
but is also a major procurer of goods and services. Their operations have the potential to
benefit local economic development, particularly in the remote, rural and islands
communities across Argyll and Bute, and might therefore be considered a relevant body.
This is also the case for Crown Estate Scotland through its land and asset management
activity. 
It is noted that Social Security Scotland is not on either of these lists. However, given its role
in addressing inequalities its inclusion should be considered. In addition, some of the public
bodies listed under the ‘specified’ category are national organisations that do not have an
operational presence in remote or rural Scotland. The inclusion of these over bodies with
more direct local impact, as noted above, raises questions around the criteria used in
classification. 
The Argyll and Bute Rural Growth Deal also presents an ideal opportunity for alignment as a
major vehicle for investment in the local economy; so embedding CWB within the Rural
Growth Deal’s governance would strengthen the policy agenda and ensure that future
investment delivers wider socio-economic benefit. 
2 Are there any ways the law in devolved areas could be changed to facilitate
Community Wealth Building that are currently not proposed in the Bill? 
The Bill is a starting point, but further legislation reform is essential to meaningful delivery.
There is a need for better alignment with existing legal frameworks, especially in relation to
procurement, land, taxation, and community empowerment. 
Current procurement law can limit the ability of public bodies to prioritise local suppliers or
businesses. Lowering procurement thresholds would allow greater flexibility and make it
easier to retain spending within Argyll and Bute, while still maintaining best value and
accountability. Best value should not be the sole deciding factor in awarding contracts if a
CWB approach is embedded. 
There is an opportunity to explore the use of local taxation powers, such as tax incentives for
businesses that contribute to local economic development or the introduction of a local
wealth tax. Expanding housing legislation to better support cooperative and community-led
housing models could help address multiple challenges, including fuel poverty and ageing
populations. 
There is concern around the fragmented policy landscape with greater alignment needed to
support the effective implementation of CWB. For this to succeed, it must be integrated with
the wider focus on public sector reform and devolved policy areas including land use, fair
work, finance, planning, housing, taxation, and education. Alignment is also needed with
existing statutory duties related to sustainable procurement, participatory budgeting, the
circular economy, climate targets, and renewable energy development. Positioning CWB as

Page 10

a cross-cutting framework – rather than a standalone initiative – would help embed its
principles more deeply across policy and practice. 
3 Are there any potential unintended consequences to the proposed Bill? 
A key unintended consequence is the increased pressure on resources that will come with
the introduction of new legal duties, reporting requirements, and partnership structures, that
will further compound existing financial strain. Developing and implementing new
approaches in relation to CWB will be resource intensive and require new investment or
reprioritisation of existing resources as articulated in the Financial Memorandum. 
There are concerns about the absence of clear mechanisms for measuring progress. The
flexibility of the Bill is welcomed but the lack of proportionate benchmarking and monitoring
guidance could result in inconsistencies in delivery, missed opportunities for shared learning,
and challenges in holding organisations accountable. The Bill also raises the risk of creating
unmet community expectations as opportunities related to asset transfer or land use may be
explored without the necessary staffing or resources to support them, potentially leading to
reputational damage for public bodies. 
The timing of the Bill is particularly challenging due to ongoing public sector reform and
constrained resources. Without clear integration with existing policies, strategies, and
governance structures, there is a risk of duplication, increased bureaucracy, and reduced
effectiveness. 
The risk of unintended consequences could be higher in remote, rural and islands areas
across Argyll and Bute where these communities face more acute financial constraints,
infrastructure challenges, and limited staff capacity, making implementation more difficult
and potentially widening existing inequalities. Where resources are already severely
constrained, compliance with CWB requirements is likely to pull resources away from other
priorities. Conversely, more affluent areas with greater capacity may be better positioned to
implement CWB initiatives, further deepening disparities. There is also potential for
economic displacement as prioritisation of local procurement and community ownership
could inadvertently disadvantage non-local suppliers and disrupt wider economic
ecosystems. 
To mitigate these risks, financial investment and capacity-building support should be
prioritised. Robust monitoring and evaluation measures should be considered, along with
strong engagement with local communities throughout the process. Co-production should be
a central feature of the guidance to ensure that communities are empowered to shape and
help deliver CWB outcomes.

Page 11

Question page 3
1 To what extent will small businesses benefit from this Bill? 
The CWB Bill has the potential to deliver benefits for SMEs, particularly in relation to reforms
to public procurement. Simplifying tendering processes and breaking larger contracts down
into smaller lots would allow smaller businesses to bid for public sector contracts, providing
enhanced opportunities and growth potential. Expanding the use of tools such as Quick
Quote and placing greater emphasis on local supply chains could further reduce barriers and
redirect anchor institution spending into the local Argyll and Bute economy. 
The Bill’s focus on promoting generative business models – such as social enterprises,
cooperatives, employee-owned businesses, and supported businesses. However, targeted
support for these business models is required, including tailored business advice, training for
business advisers to increase understanding of inclusive and democratic ownership models,
and the development of incentives to encourage more businesses to adopt these models.
Reviewing current tax rules that may discourage inclusive ownership could also be
beneficial. 
Small businesses may also need support to become ready to bid for public sector contracts,
including support with fair work practices, succession planning, and building resilient and
sustainable business models. Without such support, smaller businesses may continue to be
disadvantaged compared to larger firms with more resources and experience in navigating
complex procurement processes. It is also important to acknowledge that the Argyll and Bute
area does not have a sufficiently diverse or extensive local supplier base to fully realise the
ambitions of the CWB approach to procurement, and flexibility will be essential. 
2 To what extent will local community organisations benefit from this Bill? 
The Bill offers potential benefits for local community organisations, particularly by enabling
greater influence over local economic development. However, the extent of the benefits will
depend on how effectively the Bill is implemented and supported in practice. 
There is potential for community organisations to play a greater role in shaping local
economies, including through improved access to land and buildings via community
ownership and asset transfer, and through increased involvement in local planning and
decision-making. Greater access to assets could help grow community-led development.
However, many community organisations have limited resources, and, without targeted
capacity-building, there is a risk that only the most well-established organisations will be able
to take advantage of opportunities. 
Community organisations may also benefit from increased local investment by anchor
institutions, and from greater opportunities to shape their communities through enhanced
consultation and engagement. Implementation of CWB has the potential to help build a more
sustainable Argyll and Bute economy – supporting a stable population, securing
employment, delivering higher wages, and using local assets more effectively – contributing
to reduced inequality, improved wellbeing, and enhanced resilience. However, realising
these outcomes will require inclusive and accessible implementation, underpinned by
sustained support. Capacity-building and long-term planning are critical to ensuring equitable
participation and avoiding reinforcing existing disparities.
Appendix 2: Argyll and Bute Officer Response to the Cruise Ship Levy Consultation

Page 12

Question 1
Do you support giving local authorities the power to create a cruise ship levy in their area, if
they wish to do so? 
√ Yes 
No 
Don’t know 
Please provide the reasons for your answer.
Question 2
What alternatives (if any) do you think would achieve the same goals as a cruise ship levy?
Please provide details of any alternative option(s).
If appropriately designed and implemented, a Cruise Ship Levy could unlock
transformational socio-economic benefits for communities across Scotland and
improve the nation’s cruise offer by: 
1) Supporting long-term investment in destinations:
• A Cruise Ship Levy would provide a means for destinations to support and
harness the opportunities of cruise tourism while enabling cruise lines and
their passengers to contribute to the places they visit.
• With tight and uncertain public sector budgets, year-on-year, the proceeds of
a Cruise Ship Levy would help local authorities to maintain services and
infrastructure that support the visitor experience and used by residents. 
2) Forging a relationship between cruise stakeholders and destinations:
• Beyond economic benefits, one of the most significant outcomes of the
introduction of a Cruise Ship Levy would be the development of a relationship
between cruise stakeholders and destinations that could help to reshape
cruise tourism into a more sustainable model.
• Cruise lines sell the experience of their ships and our places. While they have
a relationship with those who facilitate access to destinations, i.e. ports and
shore excursion operators, cruise lines often do not have a direct relationship
with the communities they visit. The introduction of a Cruise Ship Levy would
facilitate a direct, mutually beneficial relationship between cruise lines and
destinations via local authorities whose primary obligation serving the interests
of local people and their places.
For island communities across Argyll and Bute a point of entry levy would achieve
the same goals as a Cruise Ship Levy. The introduction of a point of entry levy could
be transformational for local authorities with islands, creating a long-term framework
to support investment in local infrastructure and services. A well-designed point of
entry levy seems a more equitable option, it would enable all visitors, including those
arriving onboard cruise ships and in motorhomes, to make a much-needed
contribution towards sustaining the islands’ visitor economy. A point of entry levy
could offer an alternative to a visitor levy for island communities being charged solely
for overnight accommodation, as under the current Visitor Levy (Scotland) Act 2024.

Page 13

Question 3
What should the primary basis of a Cruise Ship Levy charge be, if introduced in Scotland?
Select one 
Tonnage of a ship 
Passenger capacity of a ship
√ Number of passengers on board a ship 
Number of passengers to disembark from a ship 
Other (please specify) 
Don’t know
Please provide the reasons for your answer. 
Question 4
In addition to the main basis of the charge, should any cruise ship levy also take into account
the environmental impact of a cruise ship? 
Yes
√ No 
Don’t know 
Question 5
Who should collect any cruise ship levy? Select one. 
Cruise ship operator 
Port operator 
Local authority 
√Other (please specify) 
Don’t know
Please provide the reasons for your answer. 
To aid simplicity in the implementation of a Cruise Ship Levy, it would be easier to
assess the levy to be paid by the number of passengers on board a ship. In
particular, the Cruise Ship Levy should be a flat rate per passenger, with actual
passenger numbers declared via their agent, reflecting existing national reporting
requirements.
The application of existing legal mechanisms and practices would ensure simplicity in
the design of legislation to enable a Cruise Ship Levy and also facilitate stakeholder
understanding and compliance. The usual charging regime for a vessel’s call into
port is completed through the designated shipping agent who acts on behalf of the
shipowner and, among other things, ensures compliance with local regulations. On
this basis, a Cruise Ship Levy could be collected and remitted by shipping agents.

Page 14

Question 6
What enforcement powers should a local authority, or other relevant body, have to ensure
compliance (and prevent avoidance and evasion) by those required to pay a cruise ship
levy? Please select all of the powers you think the body should have. 
Powers to request, and obtain or inspect, the information necessary to assess the cruise
ship levy liability of a body.
√ power to apply a penalty (e.g. a fine) if a cruise ship levy is not paid when it is
required to be. 
power to apply a penalty (e.g. a fine) if a body provides inaccurate information in relation
to a cruise ship levy, or destroys requested information. 
Question 7
Do you think the rate of any cruise ship levy should be set at a national level or should it be
for a local authority to decide? 
Set at the national level
√ Decided by local authorities 
Don’t know
Please provide the reasons for your answer. 
• There should be a balance between local and national consistency on a Cruise
Ship Levy rate. Given the unique circumstances of cruise destinations across
Scotland, with differing levels of cruise tourism, port ownership models, types and
areas of related land-based activity, and local requirements, a one size fits all
approach would not be appropriate. 
• Local authorities are best placed to understand the needs and preferences of their
local communities where a Cruise Ship Levy supports local flexibility to respond
accordingly.   
• A degree of national consistency could facilitate greater cruise stakeholder
understanding of their obligations and compliance. It could also reduce some
complexity in the design of local schemes and support local authorities in
establishing joint or regional Cruise Ship Levy schemes where appropriate. 
• In principle, council officers would be supportive of a discretionary levy that
devolves decision-making to local authorities, yet provides some overarching
principles set out in national legislation to preserve Scotland’s competitiveness as
a premier cruise destination.

Page 15

Question 8
If the rate of any cruise ship levy were to be set by individual local authorities, should an
upper limit be set at a national level? 
Yes
√ No 
Don’t know 
Question 9
Which (if any) of the following proposed actions do you believe local authorities should be
required to undertake before being able to introduce a cruise ship levy? Please select yes,
no, or don’t know for each proposed action below.
Have held a consultation to gather views from all those who will be affected by a cruise ship
levy.
√ Yes 
No 
Don’t know 
Have conducted relevant impact assessments, e.g. impact on business, equality impacts,
etc.
√ Yes 
No 
Don’t know 
Have set and published objectives for any cruise ship levy and what it was seeking to
achieve (either directly and/or through the use of revenue raised).
√ Yes 
No 
Don’t know 
Have assessed and documented the administrative burden from a proposed cruise ship levy
and any steps taken to minimise this.
√ Yes 
No 
Don’t know

Page 16

If a cruise ship levy rate is set locally, demonstrated why the chosen rate is suitable for that
area.
√ Yes 
No 
Don’t know 
Have appropriate mechanisms in place to allow for collection (and if necessary remittance)
of a cruise ship levy.
√ Yes 
No 
Don’t know 
Have made information about the cruise ship levy and how to pay it available in the public
domain, for businesses and others.
√ Yes 
No 
Don’t know 
Established an approach to monitoring and publicly reporting on revenues raised and their
use on an annual basis.
√ Yes 
No 
Don’t know 
Established an approach to monitoring and publicly reporting on the impact of a cruise ship
levy on an annual basis.
√ Yes 
No 
Don’t know 
Question 10
How should revenue raised by a cruise ship levy be used? Select one.
√ Revenue raised by a cruise ship levy should be required to be spent on facilities
and services used by cruise ship passengers and/or the cruise ship industry. 
A local authority should be able to use revenue raised by a cruise ship levy in any way it
wishes. 
Don’t know.

Page 17

Please provide the reasons for your answer. 
Question 11
Should any of the following groups be granted exemptions from payment of a cruise ship
levy?
Passengers who are 18 years or under 
Yes
√ No 
Don’t know 
Passengers who are disabled 
Yes
√ No 
Don’t know 
Passengers who are paid carers 
Yes
√ No 
Don’t know 
Crew members
√ Yes 
No 
Don’t know 
Passengers disembarking at the final port of call 
Yes
√ No 
Don’t know 
With tight and uncertain public sector budgets, year-on-year, the proceeds of a
Cruise Ship Levy would help local authorities to maintain services and infrastructure
that support the visitor experience and used by residents.

Page 18

Question 12
If national exemptions are introduced, do you think local authorities should be able to create
additional exemptions at a local level?
√ Yes 
No 
Don’t know 
Question 13
Should there be an implementation period for any cruise ship levy? (This would be a
required period to run from the time a local authority formally decides to introduce a cruise
ship levy to when it came into force).
√ Yes 
No 
Don’t know 
Question 14
If there should be an implementation period how long should it be? Select one. 
Less than 6 months 
6 months 
12 months 
One complete financial year
√ 18 months 
More than 18 months 
Question 15
What, if any, transition arrangements should apply when a cruise ship port call is arranged
before a local authority chooses to impose a cruise ship levy, but the port call takes place
after the levy has been put in place?
√ a cruise ship levy should be paid in this situation 
a cruise ship levy should not be paid in this situation

Page 19

Question 16
What impact do you think a cruise ship levy would have on the following? 
Cruise ship operators 
Very positive impact
√ Somewhat positive impact 
Neither positive nor negative impact 
Somewhat negative impact 
Very negative impact 
Don’t know 
Ports 
Very positive impact 
Somewhat positive impact
√ Neither positive nor negative impact 
Somewhat negative impact 
Very negative impact 
Don’t know 
Businesses linked to cruise ship industry 
Very positive impact
√ Somewhat positive impact 
Neither positive nor negative impact 
Somewhat negative impact 
Very negative impact 
Don’t know 
Local Communities 
Very positive impact
√ Somewhat positive impact 
Neither positive nor negative impact 
Somewhat negative impact 
Very negative impact 
Don’t know

Page 20

Local authorities 
Very positive impact
√ Somewhat positive impact 
Neither positive nor negative impact 
Somewhat negative impact 
Very negative impact 
Don’t know 
Scotland as a whole 
Very positive impact
√ Somewhat positive impact 
Neither positive nor negative impact 
Somewhat negative impact 
Very negative impact 
Don’t know

Page 21

Please provide the reasons for your answer(s). This helps with developing a robust BRIA
which considers as wide a range of impacts as possible. If there are any other groups that
would be impacted by a cruise ship levy please also list them below, together with the extent
to which you believe they would be impacted.  
The implementation of a Cruise Ship Levy would provide a means for destinations to
harness the socio-economic opportunities of cruise tourism by: 
• Supporting long-term investment. A Cruise Ship Levy would offer long-term
benefits for stakeholders through targeted investment in the public realm for which
the cost of provision has traditionally been borne by local taxpayers. With tight and
uncertain public sector budgets, year-on-year, the proceeds of a Cruise Ship Levy
would help local authorities to maintain services and infrastructure that support the
visitor experience and used by residents. 
• Forging cruise stakeholder relationships. Collaborative development and
implementation of a Cruise Ship Levy by cruise stakeholders would facilitate a
direct relationship between cruise lines and destinations via local authorities. This
could deliver mutual benefits for stakeholders, such as community capacity
building and industry access, improved visitor management, and innovative
product development, improving destinations’ cruise offer while, crucially, helping
to garner and maintain local support for cruise tourism. 
• Enabling viability of other levies. Crucially, the availability of multiple
mechanisms to generate revenue from tourism is especially vital as it could enable
the viability of levy schemes which may not be practicable on their own. 
Conversely, a Cruise Ship Levy could potentially have the following adverse effects: 
• Increasing costs. A Cruise Ship Levy would increase the cost for cruise lines to
visit Argyll and Bute, which would likely be passed on to their passengers and
reflected in higher-priced cruises. However, the long-term investment enabled
through a Cruise Ship Levy would significantly improve the visitor experience,
increasing perceived quality and value for money and providing justification for a
levy. 
Additional administration costs would also be introduced for whomever is liable to
collect and remit the levy to the local authority (e.g., ships’ agents). This cost
would likely be passed on to cruise lines who would, in turn, recover it from their
passengers. 
• Limiting cruise tourism. A Cruise Ship Levy could limit visitor numbers or even
deter cruise tourism, which would not only restrain local economic opportunities
but could also potentially compromise Scotland’s attractiveness as a cruise
destination.

Page 22

Question 17
Would the name ‘cruise ship levy’ be appropriate for a potential levy as explored in this
consultation paper? 
Yes 
No
√ Don’t know 
If you believe another name would be more appropriate please suggest it below. 
Question 18
Do you believe local authorities with islands should be given the power to create a broader
‘point of entry’ levy for one or more islands in their area, if they wish to do so? 
√ Yes 
No 
Don’t know 
Please provide the reasons for your answer. 
The introduction of a point of entry levy could be transformational for local authorities
with islands, creating a long-term framework to support investment in local
infrastructure and services.  
Such a levy would be more equitable and apply to all tourists / visitors and not just
those on cruise ships. Consideration should be given to amending the Visitor Levy
legislation to enable this and create a wider tourism base of those required to pay a
levy (e.g. motorhome owners and cruise ship passengers) and removing the onus for
accommodation providers to collect.

Page 23

Question 19
If there any other points you would like to make in relation to a potential cruise ship 
levy that you have not been able to make elsewhere in this consultation, please add 
them below. 
Supplementary information to previous questions: 
Question 4 – A Cruise Ship Levy should not consider the environmental impact of a
cruise ship. This would add a level of complexity to the levy scheme. It would also
exclude consideration of the environmental impact of cruise’s related land-based
activity as environmental levies on all vessels calling into the harbour areas are
already applied in many areas. The Environmental Port Index records where visiting
cruise vessels voluntarily provide details on their emissions to participating ports to
allow them to understand the emission rates and then define charging strategies. 
Question 6 – Assuming a Cruise Ship Levy would be based on passenger numbers,
with vessels and their agents required to declare these as part of the reporting
process, the need to request additional information for levy charges would be
eliminated. It is understood that legislation would require a robust enforcement
clause and the inclusion of a provisions allowing local authorities to add charges to
unpaid levies should be sufficient. Cruise ships frequently call at multiple ports within
the same regions, and there is little evidence of non-payment, as the risk of brand
damage is too high. A cruise line unwilling to pay a Cruise Ship Levy would likely
avoid booking calls at the relevant port. 
Question 15 – A Cruise Ship Levy should apply to port calls booked before a local
authority has decided to introduce a Cruise Ship Levy, provided there has been an
implementation period of a minimum 18 months.