A structure is a snapshot of a use pattern, and patterns drift. Routes change, the base moves, charter starts or stops, and the file that was correct at signing quietly stops matching reality. We review an existing structure against how the aircraft is flown today and realign it — with the smallest set of changes that makes the position defensible again.
The point of a review is not a list of worries; it is a ranked exposure map and a plan to close it. Each deliverable is built to be acted on.
The current structure and documents read against today’s usage, with each gap ranked by how likely it is to be reassessed and what it would cost.
The smallest set of changes — to ownership, lease, operator, import or records — that brings the position back into line, in priority order.
The logs, manifests, pricing and documentation to maintain so the structure stays aligned as the aircraft’s use keeps changing.
Almost no structure fails because it was wrong on day one. It fails because the aircraft’s use moved and the file did not move with it. The jet that was bought for international charter is now flown mostly privately. The aircraft registered and structured for a Geneva base now lives on the Riviera. The temporary-admission position that fitted a season of visits now describes an aircraft that has, in substance, been based in the Union for two years. Each drift is small and reasonable in the moment; together they open a gap between what the documents say and what the flight log shows.
That gap is exactly what a modern audit is built to find. Tax administrations in Italy, Spain and France compare flight activity, passenger profiles and base reality against the structure on file, and civil aviation regulators test whether the named operator is the real one. A structure that no longer matches the flying is reassessed on the flying — retroactively, with interest and penalties, and often with input VAT clawed back. The cost of correcting a drifted structure before that happens is a fraction of the cost of defending it afterwards.
A review puts the two side by side — the file and the reality — and measures the distance between them. Sometimes the distance is small and a records fix closes it. Sometimes a lease needs redrafting to match how the aircraft is actually operated, an ownership chain needs simplifying, or an import needs regularising. The discipline is to do the least that makes the position defensible, not to rebuild for its own sake.
Owners are rightly wary of being sold a full restructure when a targeted fix will do. Our bias is the opposite: find the specific gaps, rank them by exposure, and close the ones that matter with the least disruption. A good alignment often changes very little on paper and a great deal in defensibility.
The same mismatches recur. A review checks each against the current flight log and base reality.
| Area | What drifts | The exposure |
|---|---|---|
| Use profile | Commercial case thins as private flying grows | Article 148 exemption no longer supported |
| Base | Aircraft re-bases to a new jurisdiction | New tax nexus; import position reopened |
| Lease | Operation changes but the lease does not | Label no longer matches practice |
| Substance | SPV decision-making lapses | Look-through under ATAD / PPT |
| Records | Logs & manifests kept inconsistently | A genuine case that cannot be proven |
Most reassessments trace to one of these rows. A review finds which ones apply to you and ranks them before they are found for you.
An inspector does not assess the structure as it was designed; it assesses the aircraft as it is flown, then checks whether the file still supports that. The flight log and manifests show who flew and where. The base reality — where the aircraft is hangared and maintained — shows which jurisdiction has the real nexus. The lease and operational records show whether the operation still matches its characterisation. The SPV’s governance shows whether substance has quietly lapsed. Where today’s reality has moved away from the documents, the documents lose, and the reassessment follows the reality.
This is why alignment is a maintenance discipline, not a one-time event. An aircraft is a moving asset in every sense, and a structure that is not reviewed as the flying changes is, by default, drifting toward exposure. The owners who stay out of trouble are not the ones with the cleverest structures; they are the ones whose structures are kept honest about what the aircraft currently does.
A review gives you that honesty on your terms — found and fixed deliberately, rather than discovered in a query. And where a query has already arrived, the same work becomes the basis of a measured response: understand the real exposure, correct what can be corrected, and present a position that reconciles rather than one that invites escalation.
Generalised, with no client detail — an illustration of the reasoning, not a promise of an outcome.
A jet was structured at acquisition for an active charter programme, with an Article 148 exemption and recovered input VAT. Two years on, the owner flies it mostly privately, the charter has dwindled, and the records have become patchy — but the exemption is still being claimed. The file now describes an operation the aircraft no longer runs: a reassessment waiting for a query.
The review ranks the exposure, and the realignment does the least that works: it either rebuilds a genuine charter element to support the exemption, or recognises the shift to private use and restructures the VAT position accordingly — whichever matches the owner’s real intentions — and installs a records regime so the position stays aligned going forward. The gap between file and flying is closed deliberately, before anyone else closes it.
Drift is rarely dramatic; it accumulates. The first and most common mistake is simply not reviewing: a structure is set up carefully at acquisition and then treated as finished, while the flying changes underneath it year by year. The second is updating the aircraft’s use but not the file — the charter programme winds down, the owner flies privately, and the Article 148 exemption keeps being claimed on an operation that no longer exists.
The third is re-basing without restructuring: the aircraft moves from, say, a Geneva base to the Riviera, creating a new tax nexus and reopening the import position, while the ownership and register stay as they were. The fourth is letting substance lapse — the SPV that once had real management becomes a dormant shell, exposing the whole structure to look-through under the anti-abuse rules. The fifth is the records gap: logs and manifests kept diligently at first, then patchily, so that a genuinely defensible position cannot actually be demonstrated when it matters.
What these have in common is that none of them is visible until it is examined — and by then it is being examined by someone else, on their timetable rather than yours. The remedy is unglamorous and cheap relative to the exposure: review the structure against the current flying, close the specific gaps that have opened, and keep a records regime that holds the file and the reality together as the aircraft’s use continues to move. Owners who stay out of trouble are not the ones with the cleverest structures, but the ones whose structures are kept honest about what the aircraft does now.
Because the aircraft’s use has almost certainly changed since. Structures rarely fail on day one; they fail when routes, base or the charter mix drift and the file is not updated. A review confirms whether yours still matches the flying — and, often, the reassuring answer is that only small fixes are needed.
Only if the facts require it, which is uncommon. Our bias is the smallest effective change: find the specific gaps, rank them, and close the ones that matter with the least disruption. A good alignment usually changes little on paper and a lot in defensibility.
Yes. The same review becomes the basis of a measured response: we establish the real exposure, correct what can be corrected, and help present a position that reconciles with the flying rather than one that invites escalation. The sooner we start, the more room there is to act.
Annually as a default, and whenever something material changes — a new base, a shift in the charter mix, a change of operator, a significant change in routes. Alignment is a maintenance discipline, which is why we offer the review as a standing annual engagement.
The current structure and key documents — ownership chart, lease, operator arrangements, import papers — and the flight and usage history. From those we can map the exposure and set out the realignment. We will tell you exactly what is needed before we start.
We will read your structure against how the aircraft is flown today and set out the realignment — in writing, within two business days.
Four details to start. We reply within two business days — or reach us on WhatsApp for a faster first word.