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HMRC internal manual

Air Passenger Duty

HM Revenue & Customs
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Registration: Fiscal representatives

General policy

The general policy covering fiscal representatives can be found in Notice 550 Air Passenger Duty.

Note: A fiscal representative does not have to be someone directly involved in the airline industry; it can be any person(s) with a business establishment in the United Kingdom, for example a solicitor or an accountant.

The name of the appointed fiscal representative will be included in the APD register entry relating to the operator being represented.

What to do if a fiscal representative ceases to act

On receipt of notification from a fiscal representative that they are ceasing to act,you must take the following action:

Step Who Action
1 CCU Issue letter to aircraft operator requesting details of their new fiscal representative.
2 CCU Send to the CAT a:
  • copy of the letter from the fiscal representative;
  • copy of the letter to the aircraft operator; and a
  • memo requesting that the CAT confirms that an APD return is to be issued for the period up to the date that the fiscal representative ceases to act.      
      3 CCU Set an inhibit to prevent any further outputs being issued to the fiscal representative until the local officer has confirmed the action to be taken.
      4 CAT- on receipt of the above information Contact the fiscal representative and explain that they will receive a return for the period up to the last day they are ceasing to act and that this should be completed and returned as usual.
      5 CAT Contact CCU to confirm that the final return can be issued.
      6 CAT Consider whether to audit the records at this time to ensure that the APD liability is correct.
      7 CCU - on receipt of details of new fiscal representative Notify the CAT with the details of the new fiscal representative.
      8 CCU Issue a return to the new fiscal representative for the period:

From: the day after the previous fiscal representative ceased to act for the principal.

To: the last day in the period subsequent to the period in which the fiscal representative ceased to act.

Failure to appoint a fiscal representative

Overseas airlines who have no business or fixed establishment in the UK are obliged to appoint a fiscal representative. Should an airline refuse to appoint a fiscal representative we have the power after 90 days and on notification, to make its handling agent jointly and severally liable for the duty.

The decision to make a handling agent jointly and severally liable is appealable, so such a decision cannot be taken in an unreasonable manner. It is only a power to notify handling agents of future liabilities.

If you are considering either:

  • notifying a handling agent of his compulsory appointment as a fiscal representative; or
  • notifying an agent of his liability for future duty when a debt has been outstanding for 90 days,

you must contact the CAT before taking any action.

The letter of notification should allow 60 days before it becomes effective. This is to enable handling agents to review contracts with their principals and make the necessary arrangements.