A tourism destination is defined as an open, complex and adaptive system in which numerous relations in the economic, social and environmental spheres are generated. This paper aims to define a conceptual model of tourism destination management as a complex system and to identify the role of entrepreneurs as key stakeholder in a tourism destination. The main methodological approaches were systems thinking and system dynamics. A Causal Loops Diagram (CLD) enabled to cover the complexity of the tourism system and to identify relations among a number of stakeholders and elements in a tourism destination. The authors identified crucial elements of the entrepreneur sub-system involved in a high number of causal loops to establish the importance of entrepreneurs in the destination management system. Profits of individual entrepreneurs and the occupancy of hospitality and tourism services represent the model’s most frequent variables from the entrepreneurs’ perspective.