Hospitality New Zealand

Transcription

1 Hospitality New Zealand TO MINISTRY OF BUSINESS, INNOVATION AND EMPLOYMENT on: International Visitor Conservation and Tourism Levy; Electronic Travel Authority; and Immigration Fees and Levies (Joint Submission) July 2018 CONTACT DETAILS: Hospitality New Zealand Contact: Nadine Mehlhopt Phone:

2 About Hospitality New Zealand 1. Hospitality New Zealand (Hospitality NZ) is a member-led, not-for-profit organisation representing approximately 3,000 businesses, including cafés, restaurants, bars, nightclubs, commercial accommodation, country hotels and offlicences. 2. Nationally, the hospitality sector, which includes accommodation and food service operations 1, consists of 21,345 enterprises in 22,833 locations. Collectively these enterprises employ around 164,000 people. 3. Hospitality NZ has a 115-year history of advocating on behalf of the hospitality and tourism sector and is currently led by Chief Executive Vicki Lee. 4. We have a team of 8 Regional Managers around the country, and our National Office in Wellington. We have our own in-house Solicitor, in Wellington, who specialises in employment and alcohol licensing matters, as well as advising on the entire range of hospitality-related statutes and legislation. Our team is available 24/7 to members needing assistance, advice and guidance, and we have over 130 written resources available to members. 5. The Hospitality New Zealand Wellington-based team and the team of Regional Managers provide guidance and assistance to members to ensure they are educated about and adhere to the legal requirements that apply to their businesses. 6. This submission relates to the proposed International Visitor Conservation and Tourism Levy; Immigration Fees and Levies; and the Electronic Travel Authority as set out in the consultation documents. 7. Enquiries relating to this submission should be referred to Nadine Mehlhopt, Advocacy and Policy Manager, at nadine@hospitality.org.nz or Executive Summary 8. Hospitality NZ generally supports the intent of the three proposed Border Changes. 9. It is, however, our view that a wider national discussion and comprehensive integrated strategy is needed around both the broader issues related to conservation, tourism, and tourism infrastructure, along with the wider issues of immigration particularly around the current skills and labour shortages in New Zealand. 1 Statistics NZ - New Zealand Business Demography Tables

3 Specifically, issues of immediate concern to our members, which have failed to be properly considered, include: a. Freedom Camping and the use, or misuse, of public facilities; b. Regional Councils imposing, or proposing to impose, targeted rates, or bed-taxes on an ad-hoc basis, and only on commercial accommodation providers; c. The explosion of the unregulated peer-to-peer accommodation market (for example Airbnb) and it s impacts on, and failure to properly contribute towards, regional and national tourism infrastructure. d. The need to ensure an appropriate immigration policy, which includes work visa considerations, so that we can fill short, medium, and long-term workforce shortages. 10. Hospitality NZ surveyed our members, and three prominent themes in addition to the above emerged: a. There needs to be allocation of, and reinvestment of the GST collected from international visitors into tourism infrastructure and conservation; b. There is support for specific user fees and charges on all international visitors for things like Great Walks, National Parks, and Department of Conservation facilities; c. Concerns have been raised that there has been no apparent care, assessment, or regard from MBIE to streamline its internal costs and ensure efficiencies 11. Our position is that any International Visitor Levy should be carefully assessed but should be the preferred alternative to regional councils imposing a targeted rates or bed-tax on commercial accommodation providers. International Visitor Conservation and Tourism Levy 12. Hospitality NZ supports the International Visitor Conservation and Tourism Levy (IVL) in general, and a survey showed that 75.9% of our members also support it. 13. The survey of our members showed that respondents considered between 50-60% of the IVL should be dedicated to Tourism, and between 40-50% to Conservation. (Average split % Tourism and 45.1% Conservation). 14. The majority of respondents considered that the levy should be set at $30 or higher, though there was some support for $25 as the correct level. 15. The majority of respondent comments highlighted that, while supportive of the IVL, there needed to be greater investment of the GST already collected from international visitors, and that Tourism and Conservation should go hand-in-hand as mutually important to each other. 16. The consultation document does not detail how the IVL fund would be administered, how it would be accessed, or what the parameters of access would be. We recommend further 3

4 detail is provided, and that all funds and their use is made transparent, with accountability attached. 17. Hospitality NZ strongly recommends that the IVL is carefully assessed but that it should act as the alternative to regional councils imposing targeted rates or bed-taxes on commercial accommodation providers. 18. Other feedback to note: a. Majority support for additional and specific international visitor user-pays fees for conservation-related activities like National Parks, Walking Tracks, and Department of Conservation facilities etc; b. Funds collected should be spent on areas where it is most needed; c. Funds collected should not be consumed by unnecessary administration costs and MBIE should ensure that costs of collecting and administrating the funds is absolutely minimised; d. That crew (air, cargo, and ships) should be exempt from the fees; e. That the levy be renamed the International Conservation and Infrastructure Levy to make it clearer to those paying it what its purpose is. There is concern that by using the word tourism, visitors may infer they are being punished for visiting New Zealand. Which projects should the IVL be spent on? 19. Our members ranked the examples set out in the consultation document in the following order: 1. Local infrastructure / amenities such as toilets, car parks, water supply, playgrounds, and walking tracks. 2. Protecting the values of our wild places / iconic destinations. 3. Conservation visitor infrastructure and facilities. 4. Strategic investments to support tourism development in emerging regions. 5. Support for system changes that create sustainable funding sources for local infrastructure. 6. Conservation and biodiversity activity. 7. Developing other visitor attractions. 8. Support for tourism businesses such as business incubators and skills development. How should the tourism sector, local government, and/or other stakeholders inform the decision-making process? 20. Hospitality NZ s position is that the Tourism sector needs to be a full working partner with Local Government on this issue. 4

5 21. The Tourism sector must be properly represented on any advisory panel or fund management panels to help ensure that funding goes toward items of most need, and that tourism-needs receive an appropriate share of the funding. 22. MBIE should provide further information as to an outline, or best practise, of how the funding decision making process should work. All decision-making needs to be transparent and made available to the tourism sector. 23. In whatever way the decision-making process is decided, administration costs of managing and distributing funds should minimised and efficiencies made the costs, as well as funding projects, must be transparent and made available to the tourism sector. It is important that any methods of applying for funding is not overly expensive or laborious. 24. Hospitality NZ is happy to work with MBIE, Local Government, Tourism Industry Aotearoa, and other stakeholders on this item of discussion. Electronic Travel Authority (ETA) 25. Hospitality NZ supports an ETA. Our member survey respondents also indicated 77.2% support of an ETA % of survey respondents supported collection of the IVL by other means, or in a different form, should the ETA not proceed however, Hospitality NZ and its members do not support bed-taxes, or other forms of collection that would only target commercial accommodation providers, or just one type of business. 27. Our members indicated support of either a tax/levy collected on arrival in New Zealand, a departure tax/levy, or as part of passenger transport fares, as the preferred options, should the ETA not proceed. As previously indicated, our members support additional, separate, and specific user-pays fees for use of our National Parks, Walking Tracks, and other DoC facilities. Immigration Fees and Levies 28. Hospitality NZ supports cost recovery of visa processing and administration costs in general. Our member survey respondents indicate 59% support for the proposed changes across different visa categories. 29. The hospitality sector is forecast to require around 10,000 more people by 2020 to fulfil sector requirements 2. There is not currently enough work-ready and experienced New Zealanders available to fill those shortages. Hospitality NZ s view is that consideration 2 Short-term Employment Forecasts: skills/labour-market-reports/forecasting/short-term-employment-forecasts/short-term-employment-forecasts may

6 therefore be given to lowering the costs of, (or at least not increasing by much), work visas for positions on the long-term skill shortage list such as Chefs. 30. However, we submit serious concern around Immigration New Zealand s 2016/2017 overspend of budget by $11.3 million forecast to reach a $50 million deficit by the end of There needs to be much more accountability, care, assessment, careful cost/benefit analysis, and regard from MBIE to streamline costs and ensure efficiencies. Government Departments need to be able to justify and account for all spending, over-spending, and ensure costs are minimised. 31. Hospitality NZ surveyed our members and feedback of note was: a. That perhaps as visa volumes in any category fluctuate regularly, fee changes should be distributed across all categories; b. There is support for not decreasing some fees (e.g.: group visas and student visas) since there is no evidence that visitors object to paying these fees currently, and that will assist with any fluctuations in other visa categories over time. c. Concerns that any extreme free increases particularly those proposed for work visas may reduce the number of applicants. d. The approach should be for the Department to become internally more efficient, first and foremost, not to collect more funds to fuel the inefficiencies. e. In relation to employer accreditation fees being increased, feedback was relatively evenly split between support (36%), do not support (31%), and don t know (33%) Other issues or factors that should be considered for this fee and levy review, and matters to bring to Government attention: 32. Recurring feedback from our members was around the need for government departments to seriously minimise costs and maximise efficiencies. Costs should not be permitted to spiral into a 2016/2017 deficit of $11.3 million dollars and left to climb to a $50 milliondollar deficit by the end of 2018 under the assumption that those costs can just be passed on. 33. Hospitality NZ again submits that any changes to fees and levies should replace any regional councils imposing targeted rates (or bed-taxes ) on commercial accommodation providers, or any one business type, and that the government should properly assess and consider this specific issue, which is of key concern to our members. 34. There should be a proper review of all Australian and New Zealand Standard Classification of Occupations (ANZSCO) codes. Current ANZSCO codes are not fit-for-purpose for the hospitality and tourism industry. 3 page 7 6

7 35. That Restaurant/Bar Manager positions be returned to the immediate skill shortage list to assist with the continued labour shortages hospitality is experiencing for those positions. 36. That greater rules and scrutiny be placed on Immigration advisers, particularly those advising migrants to New Zealand. 37. That the process and experience for employers dealing with Immigration New Zealand be simplified and become more employer-friendly. 38. That it be made easier to make an application for those on the long-term and immediate skills shortage lists, and those applying for essential skills visas. 39. That be more work be done to implement systems that reduce the cost, and increase the assistance, for small to medium business to find suitable and capable staff whether those staff are NZ citizens, or not. Bed Taxes, Targeted Rates, and Freedom Camping 40. The Government wants to relieve pressure on ratepayers and communities struggling to cope with the pressures of rapid tourism growth. The Minister has said We need a smarter way to fund the great infrastructure tourists need to make the most of their time here. The Government is using this opportunity to re-think current funding arrangements to better align those who pay for infrastructure with those who benefit from it. This will enable sustainable growth, which enables New Zealanders to continue to enjoy the benefits generated by the tourism sector. 41. In addition, consultation documents repeatedly refer to things like Fair distribution of costs, aligning those who benefit from publicly-provided infrastructure with those who are paying as closely as possible. 42. The document released as official information regarding the IVL 4, it states [16] Across the tourism system, costs and benefits are not well aligned, resulting in free rider problems. 43. Hospitality NZ considers that peer-to-peer accommodation providers (for example Airbnb, Book-a-bach etc), and freedom campers fall into the free rider problem category. As we have seen, the unregulated peer-to-peer accommodation industry has exploded into New Zealand over the last few years. In 2017, Airbnb alone hosted 1.4 million guests over 1.5 million nights 5. Those properties are operating as commercial accommodation businesses and should therefore be treated as businesses, and regulated as such. 44. Currently, while a lot of councils have recognised peer-to-peer accommodation as an issue, very few have actually proceeded to rate peer-to-peer accommodation accordingly and Deloitte Access Economics Economic effects of Airbnb in New Zealand 7

8 align them with traditional commercial accommodation providers. The councils that have gone someway to addressing the issue have had problems identifying those properties As the Government has already identified, there needs to be alignment with those who are benefiting and those who are paying. Bed-taxes, targeted rates, or any other local or national regulations, fees, and charges that are charged only on traditional commercial accommodation providers would not achieve the Government requirement, plus it does not capture other sectors such as activity providers, retail stores, food and beverage, or transport providers etc. 46. There also needs to be better regulation of, contributions from, and management of, Freedom Campers particularly as there needs to be investment into the amenities and infrastructure they are currently using for free. 47. If the issues above cannot be addressed through this current review, we would expect that regulation of peer-to-peer accommodation and freedom camping will be reviewed under the other initiatives put in place section, especially as The Minister of Local Government is initiating an inquiry into local government costs and revenue. Visitor infrastructure issues would be within scope of the inquiry s investigations. 48. Hospitality NZ therefore reiterates our view that a border levy should replace any local targeted rates, or bed-taxes. Conclusion 49. Thank you for the opportunity to submit on the proposed International Visitor Conservation and Tourism Levy; Immigration Fees and Levies; and the Electronic Travel Authority as set out in the consultation documents. 50. Hospitality New Zealand is committed to continuing to work with MBIE, INZ, the Government, and other stakeholders on this proposal and the future changes that may come from it. Ends 6 8