European tax authorities and civil aviation regulators do not audit the paperwork — they audit the flight log, the passenger manifest and the place where decisions are actually taken. We design ownership, VAT and operations so the file still reconciles years after the first departure.
Germany-based advisory · inside the EU perimeter, not offshore.
Five documents, one adviser — reconciled before the first flight.
A registry is a mailbox. An audit looks at where the aircraft sleeps, who sits in the cabin, and who signs the decisions.
We do not sell these in isolation. A file that is right on VAT but weak on operational control fails the same audit as one that is wrong on both. Each engagement ends in a defensible, documented structure.
SPV setup, jurisdiction selection and VAT positioning, designed around the mission profile.
Operation through AOC holders, charter models and the framework that makes commercial use defensible.
Structures for non-EU principals flying into the European market and its VAT perimeter.
Import positioning, temporary admission and inward processing relief at the point of EU entry.
Bringing an existing structure back in line with how the aircraft is actually flown.
When exemption applies, how it is evidenced, and where structures break under scrutiny.
Most engagements open at acquisition, or at the moment an existing structure is questioned. Each stage produces a document you can act on and put in front of a bank.
Current or planned structure, actual usage, base of operations and flight pattern read against EU VAT and regulatory exposure. Output: a written exposure map.
SPV configuration, lease model, jurisdiction and AOC alignment — each choice tied to operational reality, not a headline rate. Output: a structure memorandum.
Incorporation, operator coordination, legal documentation and alignment with banking and financing. Output: an executed structure.
Continuous review against changing flight activity, ownership and regulatory practice — the only real defence against reclassification. Output: an annual position review.
A structure has to pass every one of these simultaneously. We design against all four from day one.
| Framework | What it tests | Where structures break |
|---|---|---|
| Art. 148, Dir. 2006/112/EC | Genuine commercial, international use | Exemption claimed on contract type, not evidenced flight activity |
| Reg. (EU) 2018/1139 | Effective operational control under EASA | Nominal operator; owner in fact directs the aircraft |
| ATAD | Economic substance of the SPV | Registered office with no management or decision-making |
| OECD BEPS, Action 6 / PPT | Principal purpose of the arrangement | Leasing chain whose only rationale is the tax result |
How VAT actually applies to aircraft across the EU, what Article 148 qualification requires in practice, and the points at which a structure stops holding.
The previous week’s developments in aircraft VAT, customs, aviation taxes, EASA and emissions trading. For each one: what happened, why it matters for owners, and the source.
We will tell you where the structure is exposed — and what a defensible version looks like.
Four details to start. We reply within two business days — or reach us on WhatsApp for a faster first word.