Competition Law in Tourism

674 COMPETITION LAW IN TOURISM Once the declaration is presented within the Andalusian Tourist Registry, (RTA in Spanish), the activity can start. After this registration, the holder will receive a decision by the RTA and a signature code30. This code must be visible in any advertising, including online platforms. If the activity is being exercised without any previous declaration, the house will be considered as clandestine and categorised as a very serious infringement [Arts. 11 & 71.1.a) DVFT]31. However, the sanction process starts not by a non-inscription but by a non- -presentation of the declaration, which will block the registration in the RTA. In pursuit of the protection of users, Andalusian regulations demand, on the one hand, the possession of the perceptive licenses and the concurrence of minimum safety conditions and quality of the accommodation. On the other hand, the fulfilment of the obligations that facilitate the stay. When analysing the requirements and obligations included in the regulations, two remarkable absences are noted by Roca Ferández-Castanys, “the DVFT does not contemplate the necessity for a distinctive plate (…) nor the obligation to subscribe to insurance covering the civil responsibility for corporal, or material damages that people using the accommodation could suffer during the stay”32. Offering an accommodation service starts with an action related to citizen security, imposed by a State regulation. As any other tourist accommodation enterprise, these accommodations are subjected to Act 4/2015, of 30 March, for Citizen Security, therefore, administrators must fulfil obligations of information and registration of the guests. They must complete the Registry Book and present the arrival reports according to what is established in the Order INT/1922/2003 of 3 July for registry books and arrival reports of travellers within hostelry and similar businesses. The entity operating must give access to the property at the specified time. When it is not formally expressed, it should be assumed that the stay starts at 4 pm and finishes at 12 am. If the owner is not present to provide the keys and documentation, these must be transmitted to the person in charge. After fulfiling the entry report, the guest must receive an admission document as a formal contract, in which it should be the name of the owner or the entity managing 30 The codes is similar to this: VFT/AL/00000; VFT indicates that the house has tourist purposes and AL indicates the two first letters of the province; 00000 is a sequential number. 31 About touristic intermediation and online services see PÉREZ GUERRA, R. (2017). “La regulación jurídico-administrativa de la intermediación turística a la luz de la nueva Directiva de viajes combinados”, Revista Aragonesa de Administración Pública, No. 49-40. 32 See ROCA FERNÁNDEZ-CASTANYS, M. L. (2017) “¿Matando…, op. cit., pp. 2021.

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