Germany-based aviation structuring advisory

Your aircraft structure will be reassessed. The only question is when.

European tax authorities don't audit paperwork — they audit flight logs, passenger profiles and where decisions are actually made. When contract and reality diverge, VAT comes back retroactively.

StuttgartEU-based advisory, not offshore
9 jurisdictionsMT · IM · LU · IE · ES · IT · FR · DE · CH
Art. 148VAT Directive 2006/112/EC practice
EASA 2018/1139AOC & operational alignment
The cost of getting it wrong

Structuring is not the expense.
Restructuring after an audit is.

Three outcomes account for almost every aircraft VAT dispute in Europe. None of them are theoretical — all follow from the same root cause: a structure that does not match how the aircraft is actually used.

€5M–€10M

Retroactive VAT assessment

Exemption under Article 148 is withdrawn after the fact. On a €30M long-range jet, standard-rate VAT plus interest and penalties routinely lands in eight figures.

100%

Input VAT recovery denied

If commercial use cannot be evidenced, every euro of input VAT already reclaimed on acquisition, maintenance and fuel becomes repayable.

Structure void

Reclassification as artificial

Under ATAD and BEPS principal-purpose testing, leasing chains without commercial rationale are looked through entirely — and the beneficial owner is taxed directly.

The pattern is consistent. Aircraft based at Nice (LFMN), Geneva (LSGG) or Farnborough (EGLF) draw scrutiny not because of where the SPV sits, but because of where the aircraft sits. Registry choice does not survive an operational-reality test.

Structure exposure check

Six red flags auditors look for

Tick what applies to your structure. Nothing is sent anywhere — the assessment runs in your browser.

No flags selected

Start with the list

Each item corresponds to a documented ground on which EU tax authorities have challenged aircraft ownership structures.

Discuss your structure Indicative only. A binding assessment requires review of your ownership documents, lease agreements and operating history.
The regulatory layer

What is actually examined

Four frameworks decide whether a structure holds. Each has a different test, and a structure has to pass all of them simultaneously.

Art. 148 · Directive 2006/112/EC

Commercial use, evidenced

Exemption for international transport is not granted by contract type. Authorities assess flight activity, passenger profile and whether charter revenue is genuine and at arm's length.

Regulation (EU) 2018/1139

Operational control under EASA

Where an AOC operator is involved, that operator must demonstrate effective control. Nominal operator arrangements collapse the distinction between private and commercial use.

ATAD · Anti-Tax Avoidance Directive

Economic substance of the SPV

Registered office is not substance. Decision-making location, local management and genuine business activity determine whether the vehicle is respected at all.

OECD BEPS · Action 6 / PPT

Principal purpose test

If obtaining a tax benefit was a principal purpose of an arrangement, treaty and directive benefits can be denied — regardless of formal compliance with each individual step.

How we work

From assessment to oversight

Most engagements begin at acquisition or at the point an existing structure is questioned.

Step 01 · 1–2 weeks

Initial assessment

We review the current or planned structure, actual usage, base of operations and flight patterns against EU VAT and regulatory exposure.

Output: written exposure map
Step 02 · 2–4 weeks

Structure design

SPV configuration, leasing model, jurisdiction selection and AOC alignment — each choice tied to the operational reality rather than a headline rate.

Output: structure memorandum
Step 03 · 4–12 weeks

Implementation

Incorporation, operator coordination, legal documentation, and alignment with banking and financing requirements.

Output: executed structure
Step 04 · ongoing

Oversight

Continuous review against changing flight activity, ownership and regulatory practice — the only defence against reclassification.

Output: annual position review
Contact

Discuss your aircraft structure

Four questions to start. If it looks like something we can help with, we will come back with specific questions about jurisdiction, lease structure and operating history.

  • Emailadvisory@bca-aviation.com
  • Phone+49 151 61471603 — 10:00–17:00 CET, business days
  • OfficeKönigstraße 35, K35, 3. Etage
    70173 Stuttgart, Deutschland
  • CapacityWe work with a limited number of aviation projects. Each request is reviewed individually.

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