Part of our job at Martyn Fiddler is to keep up to date with the latest changes to regulation, legal and policy movements. We’ve done the hard work for you. Here is your complete guide to the latest key updates set to affect the industry in 2025.
Customs: CDS
The UK Customs frontier has seen ongoing changes since Brexit, most noticeably the introduction of a new customs system from HMRC: the Customs Declaration System (CDS). CDS replaced the previous system known as CHIEF (Customs Handling of Import Export Freight)
The integration of CDS with other government systems has seen a number of sequential upgrades and changes as it has been phased in since 2018. At the end of January 2025 new Safety and Security (S&S) declarations will become mandatory, including for goods from EU countries. These changes carry legal responsibilities that need to be complied with for CDS declarations and this may shift the responsibility depending on how you interact with agents and forwarders for your aircraft & aircraft parts imports (and exports).
Martyn Fiddler Aviation has two Authorised Economic Operator (AEO) certified companies acting as customs intermediaries within the group and is authorised to use the CDS system directly. We have been operating CDS for several years (and CHIEF previously) and are already compliant with the S&S requirements and have been supporting our aviation industry clients and colleagues with CDS during this period and will continue to do so with this and future changes.
Customs: UK Air Passenger Duty (APD):
The UK has announced a huge rise in UK APD rates, effective from I April 2026 for business aircraft. An increase in the 2025 APD rate had previously been announced.
APD is charged per passenger for both commercial and business aircraft travel. APD is separated into in bands (classified as domestic, and then bands A, B & C for international travel) which are all calculated as if the starting point of any UK flight originates in London. The duty is then applied to one of 3 passenger categories – reduced, standard or higher – depending on the class of travel which is decided by seat pitch and the size / weight of aircraft. From 2026 the higher category will apply to all business aircraft (and private aircraft) irrespective of size, value or number of seats.
From 1 April 2024
| Destination Band | Reduced | Standard | Higher |
| Domestic | £7 | £14 | £78 |
| A | £13 | £26 | £78 |
| B | £88 | £194 | £581 |
| C | £92 | £202 | £607 |
From 1 April 2025
| Destination Band | Reduced | Standard | Higher |
| Domestic | £7 | £14 | £84 |
| A | £13 | £28 | £84 |
| B | £90 | £216 | £647 |
| C | £94 | £224 | £673 |
From 1 April 2026
| Destination Band | Reduced | Standard | Higher |
| Domestic | £8 | £16 | £142 |
| A | £15 | £32 | £142 |
| B | £102 | £244 | £1,097 |
| C | £106 | £253 | £1,141 |
There is a “reform of APD for private jets consultation” currently ongoing, and open for comment until Tuesday 22 January.
Customs: Ozone Depleting Substances (ODS) License requirements – importing / exporting aircraft
All aircraft should have fire suppressant equipment on board – this may be fixed or portable. If the equipment has Halon gas type 1211, 1301, or 2402 a license is required when declaring the aircraft through the Customs Declaration System (CDS) for import (or export).
The license must be applied for by (and in the name of) the entity which is the importer (or exporter) of record. Without a license the declaration will be delayed and possibly refused or rejected. It is therefore important to get an ODS license in place as soon as possible prior to importing your aircraft.
Previously there has been no charge for the ODS license however the UK Environment Agency are carrying out a consultation (open until 13 Feb 2025) with the intention of charging for ODS licenses for new registrations from 1 April 2025. The proposed registration fee is £364, with an annual charge of £1,228. These fees would be increased annually in line with the consumer price index (CPI).
Compliance: beneficial ownership register access
At the very end of 2024 the Isle of Man Government updated the Beneficial Ownership legislation to allow for people or bodies carrying out business or activity to which the Anti-Money Laundering and Countering the Finance of Terrorism Code applies, or a business to which the Gambling (Anti-Money Laundering and Countering the Financing of Terrorism) Code 2019 applies, to access the Island’s Beneficial Ownership Register. This change is part of a wider commitment by the Isle of Man and other Crown Dependencies to improve transparency in financial dealings, making it easier for regulated businesses with appropriate requirements to perform background checks and protect against fraud and illicit activities whilst maintaining the privacy of beneficial ownership from the wider public.
However, when announcing this development, the Isle of Man’s Treasury Minister, Dr Alex Allinson, was quoted as saying; “We have also committed to set out our plans as to how we can further increase access to the Beneficial Ownership register, for those who have what is known as a Legitimate Interest. Legitimate Interest is generally taken to refer to investigative journalists and civil society groups who have an interest in combating money laundering and illicit finance more broadly. There is currently no international standard in this policy area, so we are awaiting developments in the EU…”. This suggests more beneficial ownership transparency changes on the horizon – watch this space.
Accounting: Pillar 2 – Global Minimum Tax Rules
While there are a few minor accounting updates the Martyn Fiddler team will have to consider in the coming year, one significant change being implemented during 2025 is the implementation of the OECD Pillar 2 Global Minimum Tax rules.
The rules will apply to jurisdictions (including the Isle of Man and Ireland) which have stated an ongoing commitment to align with international tax standards. The rules will ensure that large multinational enterprises with total consolidated group revenue in excess of €750 million are taxed at a minimum effective tax rate of 15% in each operational jurisdiction.
Although this is unlikely to directly affect many Isle of Man companies, it will require questions to be raised to ensure that a business’s global revenues are considered and not just those generated on the Isle of Man.
Looking further ahead there will be numerous implications of the FRS102 update in 2026 that will need to be considered and applied.
Tax: VAT rates
There will be 2 significant changes to the standard rate of VAT charged in two of the EU Member States during 2025. Slovakia will increase from 20% to 23% from 1 January 2025 and Estonia will increase from 22% to 24% from 1 July 2025. It is worth noting that Finland increased their VAT rate from 24% to 25.5% in September 2024. Please see the table below for standard rates of VAT in the EU.
Standard rates of VAT in the European Union in 2025
| Country | Standard rate | Country | Standard rate | Country | Standard rate |
| Luxembourg | 17% | Belgium | 21% | Ireland | 23% |
| Malta | 18% | Czechia | 21% | Poland | 23% |
| Cyprus | 19% | Spain | 21% | Portugal | 23% |
| Germany | 19% | Lithuania | 21% | Greece | 24% |
| Romania | 19% | Latvia | 21% | Denmark | 25% |
| Austria | 20% | Netherlands | 21% | Croatia | 25% |
| Bulgaria | 20% | Estonia | 22% (↑24%) | Sweden | 25% |
| France | 20% | Italy | 22% | Finland | 25.5% |
| Slovakia | 20% (↑23%) | Slovenia | 22% | Hungary | 27% |
There will be no changes to the ‘VAT free’ treatment for VAT ‘qualifying’ aircraft. However, it is prudent to remind all sellers of aircraft in the EU that even where there is no local VAT to account for, a local VAT registration may still be required. In each case this should be confirmed in advance in the local territory. Martyn Fiddler can assist with this via our network of local specialists.
Tax: due diligence
2025 will see no relaxation in the requirements for due diligence process checks to be completed by suppliers, in particular by tax advisers like Martyn Fiddler. Remember: these requirements apply prior to accepting advisory work.
Martyn Fiddler Tax (and any other qualified tax advisor service) are strictly regulated under Anti Money Laundering (AML) Regulations in the jurisdictions we operate. This means all client work must be reviewed according to the AML rules and must be signed off by our central compliance team before any work can begin. Depending on the circumstances these checks can be time consuming; this can lead to frustration where a fast turnaround is required to support a short notice transaction.
It is therefore crucial for any information which may be required to support client due diligence checks, to be provided as quickly as possible and ideally with the instructions to act – this allows us to provide the services needed in accordance with the client’s timetable. If you are concerned regarding what information will be required, please just ask and we can provide this in advance.
Tax: qualifications
There is an increasing focus by leading tax authorities on the qualifications held by those claiming to be tax advisors. In the UK, HMRC are now extending these concerns to related areas including customs. It is anticipated that initially a voluntary standard or experience and qualification will be applied for Customs agents and other intermediaries, with the assistance of the professional membership bodies.
To read more on this, please see our article: “There is no qualification requirement for tax advisers,”
Client services: transactional observations
In the final quarter of 2024, we saw an increase in aircraft transactions as parties from all sides and all motivations hurried to close deals before the Christmas and New Year shut down. This year felt especially busy and below are 3 things we commonly saw happening (or not happening) which impacted a smooth transaction.
Book Early
Whether you are a financier, lawyer, maintenance facility, aircraft registry, aircraft operator, corporate service provider, tax advisor or customs agent, sometimes there is a physical capacity to your work. Whilst everyone in the industry work extremely hard to ensure clients receive the service and support they need, there can be times when the sheer volume of work coming your way makes success a hard won victory. So, for those of you that can remember the advert from the UK in the 1970’s “book early!” https://youtu.be/Jhvw-eeUYH8?si=95i8YgEo814v9vnt
Know who you are dealing with
It is still surprising to see that many people involved in transactions fail to recognize the need for clarifying who is trying to sell or buy an aircraft. Getting this vital information before the ball starts to roll saves time, disappointment and potentially careers further down the track. CDD collection and identifying the source of funds in a transaction should not come as a surprise; there is a host of international legislation aimed at curbing the activities of criminals and all of us should and must be ready willing and able to comply.
What’s the rush?
From our experience and from the feedback of our industry colleagues, it is always advisable to resist (or at least question hard) the client or counterparty whose aim is to complete a transaction within an arbitrary timeframe. While the end of the year may sound good, is there really a need to rush and is it actually practicable? A serious counterparty should be happy to work with a buyer or seller to achieve a deal where everyone has the time and opportunity to work thoroughly and compliantly.
Potato/Potarto
Terminology, jargon and linguistic differences mean that what you think you are saying to someone is not always the same as what they hear you say, especially when the sides of a transaction straddle the Atlantic. Make sure you confirm goals and understanding at each step of the transaction and clarify if you think there is confusion; in our experience asking a ‘silly’ question often stops the disaster before it has the opportunity to build momentum.
If you have any questions please don’t hesitate to contact our tax, customs or client service experts here.
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