Chief Medical Officers for England’s Annual Report 2021, its significance for UK coastal tourism interests
Since its publication last week’s, I have been pondering the potential significance to tourism of the Chief Medical Officer’s for England’s Annual Report 2021, “health in coastal communities”. In his second report as CMO, Chris Witty has chosen not to major on Covid-19 but instead to look at: the health and wellbeing of coastal communities, the shared conditions and circumstances that contribute to generally poorer health and wellbeing outcomes and make recommendations, many of which have positive socio-economic consequences attached and are not simply directly health related.
For those of us who bear the scars of over two decades of fighting the coastal economic development/ regeneration, tourism/visitor economy case and, within that, the socio economic, health and wellbeing strands in coastal communities, absolutely none of what the CMO says in his report is truly “news” or brings anything brand new to the long running debate. My instantaneous reaction was disappointment, followed by the realisation that at this time, in these circumstances from this author this report used cooperatively by enough coastal destinations could be a very powerful weapon in helping shape the wider outcome of policy and strategy development and in particular the shape and nature of “levelling up” mechanisms.
The report highlight all of the self-same issues that impact on economic wellbeing in coastal destinations. In doing so it independently confirms what has been said many times before in various reports and peaks of Government interest, that to my knowledge typically fall c 4 to 5 year apart since our (British Resorts Association) 1999 Behind the Façade report first tentatively unveiled some of the socio-economic issues acting as a barrier to successful regeneration, in our case using tourism as the principal vehicle.
The CMO’s comments were covered in a number of smaller articles in broad sheet with more significant local media interest confined mainly in and around the dozen and half towns cited in the full report as case studies. That interest is unlikely to be sustained nor is it big enough to have gained political tractions. I don’t doubt that colleagues in England’s coastal destinations will now be looking at how to use the CMO’s report to best effect. However, I am unsighted as to whether this will be picked up as a public health issue, a general core socio economic issue or whether there is any thought or unfilled appetite to run with this as a parallel or separate tourism/visitor economy regeneration/economic development issue? For obvious reasons I am keen on the latter.
I will be flagging the importance of the report where and whenever I can regardless of what I am now told. However, I would welcome direction from senior “tourism and economic development representatives” within the coastal membership on where, if anywhere, you like me to formally take this? Does it need to be a coordinated effort and if so by British Destinations or some other interest grouping? I am conscious that the time to strike is probably about now, so quick and dirty may be preferable to business like but way too late to influence emerging strategies, policies and delivery mechanisms?
I would also point out that while, the report is from the CMO England, the comments that coastal towns like Blackpool have more in common with Hasting than their inland neighbours, by default, also applies to coastal towns in other Home Nation’s. It may be an English report but that not to say some of the key messages can’t be cited as evidencing to support actions, for example, within Welsh coastal towns that typically have as much, if not more, in common with English coastal resorts than they do with many other Welsh inland destinations.
I also note that the CMO’s makes recommendations on improving the granularity of national health data, in order to avoid losing sight of the detail of coastal town’s problems within the background of noise of larger area data. This for me has resonance with my concerns that elsewhere HMG may lose sight of the fine detail of socio-economic deprivation as a result of their plans to abandon mapping within the new published plans for UK wide subsidy controls, that are about to replace existing EU state aid rules. Asking for improving granularity for national health data to my mind could be used to strengthens the arguments to retaining existing granularity for key socio-economic data, for exactly the same reasons. I.e., avoiding losing sight of the true picture for want of proper investment in recording the fine detail.
I have placed the CMO’s summary report and links to the full report, that includes all the case studies, on the national strategies and policies pages of Britishdestinations.net. For most coastal practitioners the summary report should suffice, with the introduction pages 2 to 4 and the recommendations pages 22 to 25 the must reads bits if you are in a burning hurry as at the is time of year (any time of year?) I am sure you will be .
As a reminder, if you have a view on using this report to advance coastal tourism’s interests, please let me know, in particular, how, when and by, or with, whom?
Access the report directly at: https://britishdestinations.net/strategies-and-policies/
Ahead of today lifting of legal restriction in England and currently 7 August in the other Home Nations ONS have released data on public sentiment. Find it in our C-19 research page: https://britishdestinations.net/c19-research/
MHCLG published its plans for England’s High Streets on the 15 July, the report Build Back Better High Streets can be accessed at: https://britishdestinations.net/strategies-and-policies/
Half a dozen quick points:
1. With the lifting of the majority of restrictions looming in England on Monday a raft of new and updated guidance, particularly around risk assessment, has been issued both for general and industry specific usage. A very good single source of tourism and hospitality guidance, produced by Government has been distributed by VB/VE : Updated Working Safely during Coronavirus: Guidance from step 4 in England (visitbritain.com)
2. Visit Wales have published a useful update on the plans for Wales and the aspiration to move to alert state zero on 7 August: News Bulletin: “Next steps towards a future with fewer covid rules” – First Minister (govdelivery.com)
4. There has been a lot debate and noise around the problems of accessing payment of business interruption insurance (in large part now resolved?) cancellation insurance for events and other activities (ongoing) and now a number of press reports around significant increases in general and business specific premiums which are only now becoming apparent as increasing numbers of businesses hit annual renewal dates. Issues highlighted include significant hikes in director’s liability insurance brought on by a perceived higher risk of business failures, but there are many other examples. These additional costs add to the burden of doing business and are bound to impact on the nature and pace of recovery, if not the product and service costs passed on to the customer.
Are members picking up on any significant issues around increased insurance cost for local businesses? If so let us know.
I am assuming (know) event insurance remains an issue. It is far too late to influence major events for 2021, many already cancelled but we do need to look towards the implications for both destination and individual business organised outdoor and indoor events, post 2021 main season and, in particular, for both small and large events in 2022. Efforts to get Government to underwrite liabilities for some or all events have not had much traction but if problems persist efforts to obtain assistance to overcome them in some way need to be pursued.
5. I have picked up on some worrying indications that at least one Destination BID has yet to collect c 40% of its levy, way higher than normal level of resistance for what is a legal binding payment. Any updates from other destination/ tourism BIDs would be appreciated (with or without caveats on confidentiality).
It also begs questions about policies on charging voluntary fees like memberships subscriptions and participation in revenue generating commercial activities in 2021 (some didn’t charge and other didn’t receive normal levels of payment in 2020). If such voluntary or commercial charges have been made, what has the reaction and payment level been like?
6. I mentioned Subsidy Control in my last update, not an issue that everyone will be immediately drawn to. For those who are interested in the Government’s proposed new approach I have received a copy of a 2019 report from colleagues in the Industrial Communities Alliance (ICA) on the role of state subsidy which you might find informative. This can be accessed at: https://britishdestinations.files.wordpress.com/2021/07/2019-state-aid-its-role-in-rebuilding-industry-and-the-regions.pdf For any colleagues in economic development, or for those with a more specific interest in the consultation, plans and ongoing development of the new UK rules email me and I can send you copies of the ICA’s submission and other associated papers which I have not posted to the consultation page on Britishdestinations.net.
Can you help a colleague with any information, research documents, studies, policy or strategy documents on adventure and sports tourism? Please see request for help on our “Ask questions get answers page” at: https://britishdestinations.net/need-an-answer/adventure-based-tourism-research-and-studies/
Last week the biggest and one of the longest environmental prosecution in UK history was brought to a conclusion with a fine of £90 million for Southern Water for persistent and deliberate discharges from 17 water treatment works in the Thames estuary and along the Southern coast to Christchurch during the period 2010 – 2015. This follows on from a fine of £126 million levied by Ofwat 2 years ago for similar offences.
The details of the case and, in particular, the judges’ comments at sentencing are an damning indictment of the companies historic approach to business management and their motivation to priorities profit of the environment. The case doesn’t do the interests of the UK water industry as a whole any favours and, although successfully prosecuted by the Environment Agency, it does beg questions about a rouge company’s ability to blatantly break the rules and get away with it for so long, even if it was eventually challenged and prosecuted.
At £90 million the fine is high and aims to serve as a warning to all. However, set against the annual profits , typically plus £200 m pa, £622m between 2013 -2017 some of it artificially inflated by rule breaking, it is hard not to still ask the question: who says crime doesn’t pay? The company has been prosecuted and fined, but as yet those who set the policies and those who directly or indirectly reaped the financial rewards for doing so have not.
The case deserves to have much greater publicity than it perhaps has so far had. It is to be hoped that more businesses unnecessarily effected by Southern Water’s criminally negligent activities during the 6 year period covered by the case will now choose to peruse Southern Water for damages. It is also to be hoped that Southern Water spend a far greater percentage of any future profit on rectifying issue and making recompense for their passed failings.
There are several recent articles on the subject, two of the more informative are:
Three things, one covid-19 relate and two not as a reminder that there is life and critically for a trade body like ours, issues outside the pandemic and we need on keep on our radar. These are future UK public subsidy controls and adjustments to the GB Tourism Survey (GBTS).
1. Yesterday’s announcement that the 19 July would now see the lifting of covid-19 restrictions in England was on the whole welcome news for the UK based leisure, tourism, hospitality and the visitor economy in general. Businesses in England and doubtless those in the other Home Nation’s, can now look forward to the opportunity to trade at or near full capacity (or even above) during a full main summer season and do so to a larger than normal captive potential domestic audience, assuming other unforeseen limitations, like staff shortages permit. However, you look at it that has to be regarded as good news for most of the domestic tourism industry.
The apparent removal of all covid-19 specific regulation and control, the new onus on personal responsibility, set against the PM’s statement of the reality that “we must find new ways of living with the virus” does of course present some real thorny challenges around policies, practices and management of consumers, employees and businesses, particularly for our tourism’s mainly service sector operations.
Some of these challenges have already been aired publicly. As businesses now look towards a firm date for full, unrestricted opening, other potential pitfalls will doubtless start emerging as business wrestle with both the theoretical and increasingly real-world experiences. Covid-19 has not gone away, nor either have a raft of public health, consumer and employment laws, regulations, duties and responsibilities, all of which will now have to be adapted to the reality that we have to learn to live with covid-19 but now without the benefit of covid-19 specific rules, regulation and much of guidance we have recently enjoyed, or is it endured? There is likely to be a lot of trial and error and significant room for too much or too little from both consumers and businesses, based on their own interpretations and application of “personal responsibility”.
As and when you identify any issues that might require formal or informal intervention, please let us know so we can discuss these with our strategic partners and where appropriate flag them with the Government(s).
2. Last week the Westminster Government released its response to its consultation on UK subsidy control and simultaneously tabled the Bill to begin enacting its chosen solution. We have taken the view that although subsidy control, essentially the replacement for EU state aid rules, is about a much bigger piece than just tourism, tourism has been and hopefully will continue to be a major recipient of public funded support and subject to any new or adjusted controls on the use of public funding. We therefore responded to the consultation raising a few general point and principles around the pressing need for support for tourism and, in particular, support for disadvantaged areas and pockets of deprivation which are often popular tourist areas and found within them.
Much of the Government’s consultation response and all most all the Bill deals with technical financial matters beyond my pay grade and frankly my mental agility. The detail, much of it still to emerge during the Bill’s progression, will be of interest to those closely involved in public finance and the funding of regeneration and redevelopment projects. For the rest of us, there is at least one issue that should sound alarm bells for tourism and tourism-based regeneration. In the last paragraph at page 43 of the consultation there is a seemingly innocuous statement: “…. a map proscribing disadvantaged areas is not required for the functioning of the regime. However, we will further consider whether any future UK map may be relevant…”.
In our view the maps down to ward/ super input area level have been invaluable in helping levering financial support into many popular coastal, rural, urban and City destinations and have been particularly helpful in identifying island of need in otherwise largely affluent areas and thus in gaining recognition and support for problem areas that blighting the economic and commercial progression in otherwise successful communities. It isn’t of course the physical maps, per say, that are important, although maps are wonderful tools for simplifying and illustrating complex situation, but the physical collection, maintenance and presentation of the fine grain economic data needed to produce the maps down to that level of small area, high detail in the first place.
It is not of course a given that abandoning the mapping means a down grading of the complex and presumably expensive maintenance of data sets down to the level previously proscribed by the EU. However, it is not unreasonable suspicion that one could easily lead to the other and the loss of this important economic tool. I would therefore urge colleagues to raise the concern with those directly involved in public finance, redevelopment etc. to help ensure that invaluable economic data, critical to tourism redevelopment, isn’t unintentionally lost in the rush to ditch EU related regulation or to “build back better”.
In my opinion being able to identify deprivation down to ward /super input area level and, thus, being able to recognise it, wherever it exists, is absolutely critical if Government genuinely wish to deliver its levelling up agenda. I am just not totally convinced that they have identified this for themselves yet. I hope I am wrong, but just in case I am not I would like recruit members support in raising awareness of the potential issue when and wherever you can. If I am wrong there is no harm in raising it and if the suspicion has any foundation then it is well worth challenging.
See the consultation response and Bill detail via our consultation pages: https://britishdestinations.net/consultation-responses/open-consultations/beis-subsidy-control-consultation-closing-31-mar-31/
3. ONS has apparent responded to concerns that recently announced changes to GB Tourism Survey (GBTS) methodology will result in a loss of comparability and trend data by agreeing to convert the previous ten years’ worth of data, using the new methodology to rework the old survey results. This is good news in that we will have a new and apparently more accurate set of domestic statistics going forward and now a reliable means of contrasting and comparing domestic tourism performance down to regional level back to 2010 2011 (?). It does mean of course that what we thought had happened in those adjusted 10 years may be somewhat different to what the new data will now tell us. Nationally that should present too much of a problem as we are at least comparing apples with apples. Relative scale and direction of travel of what are national estimates, is what is really important, not necessarily the exact quantum.
I do, however, feel obliged to alert colleagues to these changes, not least because some of you will have been using commercial models locally that rely far more than others on aggregating regional GBTS and IPS data (IPS remains unchanged for the time being at least) than others. I don’t know for certain but I suspect some of you may have, for example, policies and strategies, funding applications and funding mechanisms linked to performance and data sets that may in someway be informed to differing degrees by historic GBTS data. At some point in the not-too-distant future some of the facts and figures you have been using as reference points may suddenly change to an as yet unknow degree. That probably isn’t too big an issue, provided it is been identified in advance and measures, if any are needed to accommodate it, have been planned or taken.
It is important to note that the changes to GBTS have been brought about as a result of concerns raised by the Home Nations Governments about the accuracy of the old methodology. ONS are responding to those concerns in a forthright and effective manner. Meanwhile we of course are still unable to derive accurate local data directly from GBTS itself. Where GBTS is used to help directly or indirectly inform local value and volume estimates, we too may need to adjust our own data collection, models and methodologies to take account of the changes in GBTS. Forewarned is forearmed. As ever, if you come across any significant potential issues arising from these changes then please let me know so I can represent your concerns.
Since its publication on 15 June I have been discussing with colleagues the implications of the recovery plan and the tasks within it largely given to VisitBritain and VisitEngland, working with industry partners to deliver. For those who have not read the plan yet a few of the higher level, strategic policy points of interest are:
The recovery plan supersedes the previous Tourism Sector Deal, including the UK tourism zone pilot proposals which are now been abandoned.
Tourism taxes remain under review but there are no current plans to introduce them.
Although the success of the Coastal Communities Fund are highlighted there was no mention of plans for it to continue beyond the current biennial round (other indicators suggest the MHCLG administered fund may be rolled in to other new national funding mechanisms).
The important role of “DMO”s has been recognised and their future structures and support mechanisms within England remain the subject of an ongoing independent review, due to report later this year.
Government will now hold a consultation on the need for and benefits of, a national accommodation registration scheme.
The recovery plan gives a great deal of detail about what Government and its agencies have done and are doing to aid tourism’s recovery and sets a small number of very ambitious goals, which are essentially to accelerate the forecasted recovery to 2019 levels by one year from 2023 to 2022 fro domestic and from 2024 to 2023 for international tourism from the median case given in the recent Oxford Economics’ scenario forecast produced for DCMS. These improvement would appear to require something in the order of £20bn additional domestic and international business above that currently forecast. in the next two years. Access the summary of the Oxford Economics report at: https://britishdestinations.net/c19-research/
Unless the original median forecasts prove to be extremely pessimistic the presumption must be that the national tourist boards and industry are going to have to work extremely hard to generate significant new and additional business, on top of that they are already working to achieve. If the reality leans more toward the latter, as we must assume, then logically that is going to require a huge number of small cumulative improvements or some really significant initiatives that enable a step change in the industries’ performance in the current and following two years.
Currently there isn’t too much detail in the recovery plan about how that additional business will be achieved, by whom and with what resource. There are reference in the plan to a number of schemes, for example rail tokens, but between them they may not yet add up to the necessary levels of stimulus needed to generate the additional business required to achieve the stated goals. Other initiatives are expected to follow and the perceived gap represents a major opportunity for the industry to make proposals to Government to fill them.
Working with our strategic partners, we will now look at any emerging detail with a view to promoting these and to champion other new or existing measures that combined will help Government achieve its aims. Some of that will be entirely down to the industry to deliver but some may require further support from Government. For example, continuance of reduced VAT levels on tourism services and/or business rate relief in to 2022 and beyond are measures that are of a scale that might help achieve the earlier 2022 and 2023 target more easily. Colleagues doubtless will have other suggestion that we would like to hear and, if appropriate, feed up to Government for their consideration.
We also note that in the recovery plan the value of domestic tourism is expressed only in terms of domestic overnight stays and that day trips, a large and very significant additional element within domestic tourism’s value and volume, are not addressed statistically or their importance specifically referenced within the recovery planning and plan. We wonder if that is a simple oversight, an error in the use of terminology, or whether it reflects a genuine deliberate omission of this normally vital and currently critical area of opportunity for the tourism and visitor economy’s recovery? Going forward we would expect a tourism recovery plan to consider the function of day visits in that recovery and to look in some detail at how substantial increases in daytrip activity might be fostered to grow tourism, particularly outside the main summer season where it is currently less concentrated.
At this week’s destination managers meeting one of the major current and predicted ongoing issue discussed was the shortage of trained workers across all skill levels and disciplines. Although the problems have already hit the national headlines they are not confined or due solely to the predictable (and identified as a potential issue as early as January see ESCE report) loss of EU worker who have returned home. British Destination members cited numerous instances of a loss domestic workers, most whom had been forced to seek or had found alternative employment in the last year and who were now reluctant or unwilling to return to work in the hospitality industry.
The view was that this was not something that would correct itself immediately and may not without intervention in the short, or immediate term. The impact on business was significant and was stopping some business opening and other operating at the current restricted levels and this would only get worse as restrictions lift and potential capacity and demand improves. Critically a once in a generation the opportunity to impress and retain for the future an essentially captive domestic audience in 2021 was being placed in jeopardy by the likely continuation of capacity and service quality issues. Large numbers of inexperienced staff and a lack of skilled staff in key disciplines is bound to impact on the consumer experience and give a jaded impression of what UK tourism has to offer.
Destination managers, thought it highly unlikely that the UK Government would move to lift “lower skilled tourism employment” migration restrictions and certainly not in time to impact on the critical 2021 summer season but, nonetheless, British Destinations should support the ongoing industry lobbying efforts to achieve some movement now or in the future. To that end it is important to understand the Government’s current position which is covered in the following summary:
Members thought it vital to look in parallel with the issues for the domestic workforce. Covid-19 had further exposed direct problems like relatively low wages combined with unsociable hours, seasonality issues etc. and indirectly related issues ranging, for example, from poor image of employment in the industry to a lack of affordable quality accommodation or housing in popular tourism areas. The majority of these were significant long-standing issues that could and would not be address quick but addressed they must be unless the industry believed that UK Government would at some point allow the industry greater access to large numbers of highly motivated, experienced overseas workers willing and able to work for comparatively low wages and in some instances live in relatively uncomfortable conditions working long and or unsociable hours. If there was ever a time to address some of the big, “elephant in the room” issues for domestic employment within the industry it was now.
UK Government has understandable put considerable emphasis on schemes like Kick Start and would in all likelihood continue to refer the industry to these schemes as immediate solutions. Members report a number of issues with obtaining staff via the scheme ranging from high degree of competition for a limited number candidates to barriers to uptake. Blackpool cited an issue with the complex paperwork which was serving as an understandable barrier to many potential candidates. In Blackpool’s case the Council had deployed staff to job centres to assist candidates with their applications generating a very large percentage increase in uptake and successful participation. This model was recommended as a potential solution to other major destinations struggling to utilise the Kick Start scheme as a means of supporting their local industry.
I thought destination mangers might like a little light relief from the daily grind of managing the issues of increased volumes of visitors against a background of restrictions on the volume and value for individual businesses. This weekend, the first Bank Holiday with the majority of business open and most people allowed to travel will be a real test of business resilience, destination management and the patience of a host of visitors which will include some new to the ways of the domestic industry and some might even suggest to the ways of polite UK society.
I am very aware that there are real background concerns and uncertainties surround what the 21 June, the target date for a further return towards “normality” and, particularly, the fact that this uncertainty will last until at least 14 June. This wouldn’t be as much an issue if it were not for the growing concern about increasingly established new variants in certain areas of the UK. One of the issues to be discussed at next week’s destination mangers meeting (more on that below).
As to the light relief I have shared a quick note with colleagues in UK Beach Management Forum about developments around “bathing rivers” of which the UK has none and only one newly established riverine bathing site on the Wharfe in Yorkshire. The growing popularity of wild water swimming combined with environmental commitments to tackle serious issue with river water quality make it almost a certainty that demands for cleaner inland rivers and the reassurance of bathing water status to go with it, will increase exponentially. That brings with it some real and potentially different challenges to those already experienced at traditional coastal of lake based site that are operated on the presumption of high volume usage, at best May to September only.
I guess my point here is that bathing water quality and the associated management of the PR pitfalls is likely to visit itself on many more UK destinations, both inland and coastal in the next decade, than it has done for the last (45 years) since it became EU prompted issue of bathing water quality in the mid 1970’s. I also suspect that it may change public understanding of bathing waters and the current single sample point, 20 tests per session regime which is at best indicative of likely standard, not a guarantee of actual quality here and now. If you have a river of any consequence, or existing coastal or inland lake bathing waters in your patch then see more via the UKBMF site at: https://ukbeachmanagementforum.wordpress.com/latest-news-and-posts-from-ukbmf/
And finally the real point of this up date is to remind all members that the next destination managers meeting, mainly to update progress in stage three and discuss prospects and actions needed for stage 4 and beyond, is programmed for 2pm Thursday 3rd June. Despite best efforts, I keep missing people who have previously participated off the invitation email distribution and don’t necessarily invite all those other welcome to attend but who may not have joined in with this invaluable national updating process. If if you wish to attend and have not had the diary invitation and link (hosted for me by Mark Catherall Sefton Council and therefore from his email address) yet then please email me at email@example.com . Happy to consider request from non-member guests where it adds mutual value. Please feel free to ask.
In the absence of anything substantive to say yet about today’s Queen’s Speech, there are a few outstanding items on UK tax and tourism from March’s Budget, its related follow-on taxation announcements and general speculation since that I feel I ought to raise with colleagues:
1. There are a few tourism related Budget tax announcements that have yet to come to fruition. Proposals to adjust Air Passenger Duty (APD) for international travel and a fundamental review of business rates have yet to be consulted upon or, in the case of the latter, is a work in progress, due to be concluded this Autumn. The third and probably the most pressing is the agreed, staged return of VAT on tourism services to 12.5% from 30 September 2021 and then back to 20% from 31 March 2022.
While the extension of the reduced rate of 5% was in the circumstances most welcome, the strategic and operational impacts of the first increase coinciding, as it will, with the end of main summer season and a return to what should, at least in normal times, be the domestic shoulder months, heading rapidly towards off season, is concerning. On reflection it could have been better timed, although whenever it came it still would be unwelcome.
Given it was a firm commitment in the Budget itself, there is now very little prospect of a change of direction, unless something untoward occurs in the interim. Something significant enough to force a change now, isn’t something any of us would wish for. We must also reluctantly accept that the announcements on VAT marks the end of the passing opportunity to secure a permanent lower rate of VAT for tourism services, off the back of Covid-19. Having lost that opportunity, a stronger more persuasive case is unlikely to emerge in the immediate or foreseeable future. I hope I am wrong in this my personal assessment.
Meanwhile, although it is just under 5 months before the first VAT increase, there is very few overt signs that individual businesses are yet considering the practicalities for their own business, let alone the combined big picture impacts on “the industry”. In part that might be because the practicalities are potentially both contentious and complicated and will vary greatly from business to business, depending largely on how they handled the original 15% “discount”. I.e., retained, shared or passed it on in full and multiple variations on those themes. Those businesses that took the easy route and simple retained their original prices and kept back the additional 15% to offset their own costs, probably have the easiest choices and the simplest solutions available to them. For others it could be far more difficult in practice or from a PR and sales prospective.
To my mind advising hospitality businesses on what to do about the impending VAT increase is not in the remit of the destination manger’s, but reminding businesses that, in some case, it will need very careful consideration and doing so well before the implementation date of 30 September might be of mutual benefit? As might reminding them that whatever they do in September will be impacted by, or have impacts upon their choices of how to handle the subsequent increase on 31 March 2022. I am sure larger businesses and most of more proactive accountants will already be all over the issues. My immediate concerns lie with some of the struggling SME’s and micro businesses who may not have ready access to professional advice and may need prompting to seek it. That said a proportion of the very small operators of course will not be registered for VAT and so dodge the problem entirely. The original HMRC update can be accessed at:
2. In the post-budget “Tax Day” announcements, there were brief references to the intention to clamp down on abuse of self-catering holiday let rules in England. There was very little detail given; essentially the moves appear to be aimed at second and holiday home owners who have deliberately reclassified their properties as holiday lets, thus paying no Council tax and, in many cases, also falling below the threshold to pay business rates but who have little or no intention of advertising and renting the property for the requisite minimum period which for England is currently available for 30 and let for 15 weeks a year. To what degree, by whom and how abuses are to be pursued, whether there are any thoughts of retrospective penalties and, now, any implications that might have for what are alleged to have been significant and morally unjustifiable, automatic payments of business rate related covid-19 support grants, remains to be seen.
Thus far, HMRC’s comments are confined to: “Strengthening the self-catering accommodation criteria for business rates – The government will legislate to change the criteria determining whether a holiday let is valued for business rates to account for actual days the property was rented, following a previous consultation. This will ensure that owners of properties cannot reduce their tax liability by declaring that a property is available for let while making little or no actual effort to do so. Further details of the change and implementation will be included in the Ministry for Housing, Communities and Local Government’s (MHCLG) response to the consultation on the business rates treatment of self-catering accommodation which will be published shortly”.
MHCLG do appear to be dragging their feet on publication of the consultation findings (consultation late 2018 early 2019) and the details of how they intend to plug this particular local and national taxation loophole. Whenever the announcements come, they are likely to be of significance, in particularly for rural and urban honeypot locations and other areas especially popular with both holiday home and self-catering, furnished holiday letting owners. It is to be hoped that genuine tourism businesses will not be adversely affected, while those blatantly playing the system are robustly and effectively brought back in to line. Achieving that difficult balancing act may be what’s delaying the MHCLG pronouncements?
Forewarned is forearmed as any announcement made, with the summer season fast approaching, are bound to provoke reaction from the media whatever their intent and their impacts may be. The quote above, paragraph 3.4. page 8 is the sole reference in the HMRC announcement of 28 March. Business rates and APD are discussed at paragraphs 3.2. and 3.3. respectively of the same page of the document: Tax policies and consultations – Spring 2021 (publishing.service.gov.uk)
3. Looking much further ahead towards the 2030 and the impending ban on the sale of new fossil fuelled motor vehicles, there has been ever increasing debate since last October about the Government’s financial need to move away from fuel duty to a pay by the mile system, in order to preserve tax revenues in the new age of electric motor transport. The reality is of course that effectively we already pay by the mile driven by dint of the fact that the further you go the more fuel you use and the more duty you pay. It just isn’t that blatantly obvious to us all that that is the reality. There are of course choices to be made about the size and type of vehicle and thus fuel consumption. Nonetheless, I would suggest that few if any of us actively consider the distance, cost ratio when travelling anywhere in what is in effect a pre-journey pre-payment system. If and when we are asked to pay a recognisable and easily identified tax charged by the mile, for each mile travelled, as we travel or soon after, then attitudes to journey distance and destination choice may well change? Equally it may just be accepted as the price you pay to drive, just as the eye watering cost of fuel (due largely to the duty added) has become?
Its potentially a decade off but could come much sooner in certain urban areas or for certain types of vehicle everywhere. If and when it comes, how will it impact of travel choices and, in particular, on discretionary travel, of which leisure and tourism are currently especially, arguably in many places entirely, dependent? I don’t suggest it is something we should be worrying about on a daily basis. However, like the subject of the provision of either: adequate charging points for unpredictable peaks of mass car borne visitor demand, finding alternative means of transporting tourist in volume to popular destinations, or in the worst case finding new purposes for those popular tourist destinations in future denied access to visitors in numbers as a potential consequence of a demise in the ownership and us of the private car, it should be up there as one of those big strategic questions. Questions that are best asked and debated now while there are still opportunities to influence general direction and not just left, as normal, to the time when it is all too late and it has become a matter of addressing the detailed, unintended consequences.
Of all the areas of Government policy, transport and anything that has to do with the cost or means of either public or private transportation is absolutely central to tourism. Anything, including taxation, that limits travel, also directly limits tourism and directly restricts and curtails the visitor economy. If you doubt it witness the impact of travel restriction on the visitor economy in 2020/21. Sadly, anything to do with travel for “discretionary purposes” like leisure and tourism, feel like it remains firmly relegated to the third-class carriages when it comes to DfT policies and priorities. This is compounded by the fact that if it is has anything vaguely to do with transport DfT take the lead in Westminster, not DCMS, regardless of the relevance of the transport issue to tourism. That isn’t a criticism just a statement practical reality and one we all need to recognise and work around; just as we need to recognise that anything to do with tourism taxation, still needs to be raised with DCMS and supported by them but ultimately addressed directly to Treasury who will make the decisions that count.