Doris Borrego, president of Ascav (Canarian Association of Vacation Rentals) and of Fapavat (Federation of Associations of Owners of Vacation and Temporary Rentals), has responded with another public letter to the open letter addressed to Jorge Marichal, president of Ashotel and of CEHAT (Spanish Confederation of Hotels and Tourist Accommodations),
Marichal had assured that "we are not against" holiday rentals, "we only ask that the same regulations be applied". In his opinion, holiday housing "must have the same administrative rigor as other sectors and activities".
For his part, Borrego, made in his letter a call for dialogue by defending that there are more points in common than differences between hotel accommodation and holiday housing of small owners.
The president of ASCAV insists on the need for consensuses to avoid division in a strategic sector like tourism and demands legal certainty for private owners.
Borrego had requested to differentiate between small owners and large operators in the regulation of tourist rentals to avoid small owners procedures typical of classified activity.
The also president of FAVAPAT recalled that The VV is not an economic activity if its owners exploit it and do not provide hospitality services according to the Tax Agency and exemplified that "if a pensioner registers for economic activity loses their pension".
Open letter from the president of Ascav and Fapavat to the president of Ashotel and CEHAT
Dear Mr. Marichal:
Thank you very much for your open letter, which allows me to clarify, once again, that the Canary Islands Vacation Rental Association (Ascav), as well as the Federation of Associations of Vacation and Temporary Rental Owners (Fapavat), which I also preside over, defends the private owners of vacation homes and the managers and intermediaries who provide services to these homes.
We do not defend in any case large investment funds, large holders or even part of their hotel associates who also dedicate themselves to vacation housing, exploiting complexes or complete buildings. That modality that today has even managed to displace with strict municipal planning regulations the traditional model in the hands of the small owner. See the example of Barcelona, Las Palmas de Gran Canaria or recently Madrid.
Following his words, as president of Ashotel and also as president of CEHAT, he has also denounced on many occasions that behind the holiday home model are “hidden” the big players that compete with their sector, but with lax regulations.
We have spoken about this on several occasions and allow me to express my impression, that at least on this point we agree, that it is not the same and that it is important to separate by definition and regulations the two models of vacation homes. For this reason, we have been fighting for more than six years.
It is true, and I agree with you, that the vacation homes I defend are “ubiquitous” and always have been, not only in Canarias, allowing the economic development of many towns, in addition to avoiding in many cases depopulation in midlands. Offering opportunities to many young entrepreneurs to create companies that provide us with services, or something that for Ascav is especially important: supporting Canarian entrepreneurship of applications and R + D development.
Ultimately, Ascav's objective is to boost the local economy and serve as a launchpad for Canarian companies outwards, something I hope will not be objected to. Furthermore, one can vote against vacation homes in homeowners' associations, should the neighbors so decide.
And the essential, which is our main claim at this moment, of declaring harmless the vacation home (VV) of private owners registered in the Tourist Register before the entry into force of Law 6/2025, is for the following reason:
VV is not an economic activity if its owners exploit it and do not provide typical hospitality services according to the Agencia Tributaria, which is the Administration that determines what is an economic activity or not, not the Gobierno de Canarias. Therefore, if in the activity classification process the City Council requires an owner to register in economic activities, as required by the Law of Classified Activities of 2011 (before VV existed in 2015), evidently all small owners in Canarias are excluded, who are more than 80% of the tourist registrations in the Community.
And we have always given the example of a pensioner who if they register for economic activity loses their pension, or of any other owner who without providing services would have to be forced to pay the self-employment regime and comply with obligations that the Agencia Tributaria does not establish for them.
Evidently, to municipally classify an activity that is not such for Hacienda, which is who determines it, generates legal uncertainty and damages to a citizenry that is willing to comply but does not know how to do it. Secondly, our mandatory use until the approval date of the new law 6/2025 of December 12, 2025, has been the residential to be able to register as VV (according to Decree 113/2015), because if the use of our properties were tourist, we could not have registered as VV and we would be subject to other regulations (Law 7/1995 on tourism planning of the Canary Islands).
Needless to say that we do not ask for the harmlessness for the buildings or complete complexes of vacation homes
“Not everything goes”
Of course, not everything goes in the vacation rental sector and we have never opposed complying with regulations, as long as they are able to be complied with. Evidently there have to be limits. But from there to ending with practically all private owners and the companies that provide services there is a big difference.
Regarding that we are cause of the housing shortage, I invite you to demonstrate that the more than 1,300 illegalized VV in Lanzarote will end the shortage of residential housing. Only legal certainty for homeowners will open the 211,000 empty for residential use and make reasonable rental prices possible.
Mr. Marichal, as I have already told you on multiple occasions, I am fully convinced that more unites us than separates us and I once again extend my hand to dialogue and reach consensus. It makes no sense that such an extremely important sector as tourism is so divided, when unity is what makes strength.
