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We start here with a reminder of the definition. There are two different types of LTA envisaged by the 2018 PTRs:

i. The separate selection and separate payment of travel services made during a single visit to a traders point of sale (e.g. at a travel Agents where the traveller selects and pays for a hotel and then, without leaving the Agent, he/she selects and then pays the Agent separately for a flight) or website (e.g. a traveller goes onto a website, selects and pays for a flight, and then while he/she’s still on the website, he/she then selects and pays separately for a hotel)

ii. The second definition refers to a traveller visiting a website and after the traveller has purchased one travel service, they are ‘targeted’ with a cross-sell to another trader’s website, where the traveller buys from that other trader within 24 hours (e.g. an airline sells a traveller a flight. In the booking confirmation email, the airline invites them to book a hotel room with to go with their flight. The traveller clicks on the link and books a hotel within 24 hours of booking the flight).

The 2018 PTRs exempt the following LTAs:

  • LTAs covering a period of less than 24 hours unless overnight accommodation is included
  • LTAs offered occasionally and on a not-for-profit basis and only for a limited group of consumers
  • LTAs purchased based on a general agreement between a travel company and another person acting for a trade, business, craft or profession for the purpose of booking travel arrangements in connection with that trade, business, craft or profession.

There is one important consideration and that would be to ensure you are not selling a package rather than a Linked Travel Arrangement. You will be if you fall within any of the package definitions, for example;

1. All the services have been selected before the customer agrees to pay for them, or;

2. You offer, sell or charge an inclusive or total price, or;

3. You advertise or sell the travel services as a package or similar term.

The fact that a customer pays separately for the travel services does not mean that it is a Linked Travel Arrangement. They must select a service and book it before moving on to select and book the second and further services for the resulting trip to be a Linked Travel Arrangement rather than a package.

Case study: A room with a ‘sea view’

An online bed bank gave a traveller a selection of hotels to choose from. The traveller purchased a hotel with the description, “The hotel has a wonderful sea view”. The bed bank took payment for the hotel and in a separate transaction, the consumer paid for a flight to the resort. This was, therefore, an LTA. However, when the consumers arrived, they found the description of the room to be totally misleading. The room had a ‘sea view’ painted on the wall which led to an investigation.

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