When the consultation opened earlier this year, we encouraged members to share their views. The response we have now submitted reflects those insights and feedback, ensuring that the concerns of agents and landlords are directly represented to the Welsh Government.
The consultation has now closed, and Welsh Government will consider the evidence gathered. Propertymark will continue to engage on behalf of members to ensure that taxation policies are fair, practical, and support the sustainability of housing markets across Wales.
Supporting flexibility but urging lower thresholds
Allowing operators to average days let over two or three years is a practical step that reflects the seasonal nature of tourism and prevents them being penalised for shortfalls in individual years.
That said, the current 182-day threshold remains too high. Propertymark has called for this to be reduced to around 120 days, which better reflects occupancy patterns while still ensuring that properties are genuine businesses. Similar flexibility should also be extended to private rented sector (PRS) landlords, who face comparable fluctuations in occupancy and would benefit from more consistent tax policies.
Recognising charitable contributions
The proposal to permit up to 14 days of charitable short-break donations to count towards letting criteria is a positive move that acknowledges the social contribution of operators who support registered charities. Clear safeguards will be needed to ensure donations are genuine and properly evidenced, and we have recommended extending the same allowance to PRS landlords who may wish to support their communities in similar ways.
Transitional support for operators
Introducing a 12-month transitional period where properties moving from business rates to Council Tax are charged at the standard rate before any premium applies would provide much-needed stability for operators and help local authorities manage transitions smoothly. Comparable transitional arrangements should also be considered for PRS landlords facing new tax or regulatory burdens, to protect the supply of homes for rent.
Wider tax and housing impacts
Beyond the consultation questions, Propertymark raised several broader issues:
- Farm diversification: Many rural businesses rely on self-catering lets as part of agricultural diversification, and policies must reflect their seasonal challenges.
- LTT surcharge: The Land Transaction Tax surcharge on additional property purchases is a barrier for landlords seeking to expand portfolios, limiting rental supply and affordability.
- Supporting local markets: Reforms must balance discouraging underused second homes with enabling responsible operators and landlords to continue providing valuable housing.
This builds on our earlier stance, when we warned that blunt taxation measures risk penalising small operators. Our position remains that reforms must strike the right balance between tackling underuse and protecting those who contribute to local housing markets.
