Therefore, the ability to charge a levy based on a flat fee was welcomed by many respondents to the Committee's call for views on the current Bill.iiWritten submissions from: Best of Scotland Holidays, Dalata Hotel Group, Destination Orkney, South Lanarkshire Council, Glen Nevis Holidays, UKHospitality Scotland, Historic Houses Scotland, Edinburgh Hotels Association, UKinbound, Falkirk Council, Village Hotels, Scottish Passenger Agents' Association, Scottish Land & Estates, Tom Marshall, Michael Breslin, Julie Rickards, Paul Phillips, Kacey George, Sheena Dinan, Kate Copestake, George Eckton, David McAspurn, Peter Leveson, Edele Murphy, Argyll and Bute Council, The Highland Council, The Scottish Tourism Alliance (STA) and The Association of Scotland's Self-Caterers -initial joint response, Booking.com, Dumfries and Galloway Council
The support for a flat-fee model was often presented alongside expression of critical views of the current percentage model,iiWritten submissions from: Best of Scotland Holidays, Holiday and Residential Parks Association, UKinbound, Village Hotels, Scottish Land & Estates, VisitArran, Kacey George, Davar Bed and Breakfast, Reserve travel ltd. including from stakeholders who were initially in favour but found it unworkable in practice.ivWritten submission from: Scottish Passenger Agents' Association Most accommodation providers, industry bodies, and some councils view a flat fee as:
simpler and more transparent for visitors.iiWritten submissions from: Best of Scotland Holidays, Glen Nevis Holidays, UKHospitality Scotland, Historic Houses Scotland, Edinburgh Hotels Association, Village Hotels, Forge Holiday Group, Loch Lomond and The Trossachs National Park, Tom Marshall, Julie Rickards, Paul Phillips, Sheena Dinan, Kate Copestake, George Eckton, Peter Leveson, Edele Murphy, Argyll and Bute Council, The Scottish Tourism Alliance (STA) and The Association of Scotland's Self-Caterers -initial joint response
easier to administer for businesses, particularly SMEs and micro-operators, specifically because of lack of a need to separate the core accommodation costs from the 'additional' costs such as parking, meals, etc., when calculating the basis for the percentage levy.iiWritten submissions from: Best of Scotland Holidays, Glen Nevis Holidays, Edinburgh Hotels Association, South Lanarkshire Council, Destination Orkney, UKHospitality Scotland, Historic Houses Scotland, Scottish Passenger Agents' Association, Aberdeenshire Council, Fife Council, Argyll and Bute Council, The Scottish Tourism Alliance (STA) and The Association of Scotland's Self-Caterers -initial joint response, Davar Bed and Breakfast
more compatible with booking systems, online travel agents (OTAs), and tour operators.iiWritten submissions from: Edinburgh Hotels Association, UKinbound, Argyll and Bute Council, The Scottish Tourism Alliance (STA) and The Association of Scotland's Self-Caterers -initial joint response, Booking.com, Reserve travel ltd.
easier for councils, in that it was thought to be less likely to generate errors, disputes, or non-compliance than a percentage-based model.iiWritten submissions from: Edinburgh Hotels Association, Scottish Land & Estates, Argyll and Bute Council, The Scottish Tourism Alliance (STA) and The Association of Scotland's Self-Caterers -initial joint response, Booking.com It would also allow for more predictable revenues.iiWritten submissions from: South Lanarkshire Council, Best of Scotland Holidays, UKHospitality Scotland, Historic Houses Scotland, Fife Council, The Scottish Tourism Alliance (STA) and The Association of Scotland's Self-Caterers -initial joint response
However, some stakeholders felt that it was not necessary to introduce the option to base a levy on a flat rate model, and pointed to the amount of work and consideration already given to all the options, calling instead for consistency in applying existing solutions.iiWritten submissions from City of Edinburgh Council, Stirling Council, Awaze, UK STAA Moreover, some respondents argued that percentage‑based levies are more progressive and future-proof, as they track accommodation price, seasonality and inflation automatically, and avoid regressive impacts on low‑cost stays.iLocal Government, Housing and Planning Committee, Official Report, 27 January 2025, Cols 8 and 15; Written submissions from: Scottish Hostels, City of Edinburgh Council;
Some submissions, including from Stirling Council, felt the flat-rate model, and different ways in which this could be applied, exacerbated complexity:
"...a landscape where each council has a choice of three different levies (i.e. a percentage, a per person per night charge, a per room charge) with differing rates within that will raise compliance costs for agents, platforms and property managers with properties in different councils, adding particular implementation challenges for online platforms which would have to set up more complex booking systems to allow for different levy calculations."