2019-02-12 Attachment 1 to Item 7 - Short Term Accom Online Platform Issues Paper

The business models of Airbnb and Stayz are such that private addresses and home ownership
details are not made public, for several reasons. Airbnb and Stayz remain at arm’s length from the
income reporting, tax obligations and income declaration of hosts, shifting the risk and responsibility
of these aspects of providing short term rental accommodation to the property owner. They also
largely shift responsibilities relating to safety onto property owners.

Council is challenged by:
   Increasing numbers of new short-term websites, making it difficult to identify and track properties
    that are made available for short-term letting.
   Difficulty proving that an identified property owner is offending or re-offending.
   The cost, time and resources required to monitor multiple websites to try and identify properties
    that are being short term rented.
   Websites electing to withhold property location and other identifying information.

The operational model of online accommodation share economy platforms such as Airbnb and Stayz
allow for concealment of property addresses and owner details, at the homeowners’ discretion. It is
important to note that these companies do not promote or suggest concealment to property owners,
instead they have cleverly and effectively used the trending share economy to transfer any risk and
responsibility of tax, safety or legislative compliance to the property owner.

Airbnb and Stayz argue that mandatory registration of addresses and home ownership information
would be a breach of their privacy rules, as the business models are supposedly peer-to-peer
arrangements, rather than commercial business operations. Arguably, Airbnb and Stayz platforms
actually facilitate a business-client arrangement, just like any other holiday accommodation.


5.4      Avoidance of the Tourism and Economic levy
In its 2018-19 budget Council introduced changes to the Tourism and Economic levy structure to
recognise identified equity issues between levy amounts for home hosted short-term rentals (when
the host is present) and entire properties being let. In the urban areas, for example, Transitory
Accommodation that is not a Principal Place of Residence (i.e. not someone’s private home) will be
rated at 0.2224 cents in the dollar of the rateable value. For Transitory Accommodation in urban
areas that is a Principal Place of Residence (i.e. a home-hosted property letting out one or more
bedrooms in their house), the rate has been set at one-third the value of a non-principal place of
residence property (i.e. 0.0741 cents in the dollar).

The clear aim of the change in charging structure was to ensure that there is equity between the
Airbnb-type host who is simply letting out a spare bedroom (these properties do not generate the
sort of amenity problems and neighbour conflicts that non-principal place of residence properties
create) and those properties which are let in their entirely and generally serve as commercial
investments.

However, there are currently likely to be a large portion of properties that are not being levied, as
Council is not aware that they are participating in the short-term rental market. Arguably, all short-
term rented properties benefit from the destination marketing and promotion paid for through the
Tourism and Economic Levy, and should therefore contribute to the cost of these activities.




Short Term Accommodation - Online Platform Response Issues Paper                               Page 19