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HMRC internal manual

Air Passenger Duty

HM Revenue & Customs
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Special accounting schemes: Reviews and auditing

When should the scheme be reviewed?

Special accounting schemes are always agreed for a specified period. At the end of that period, the scheme should be reviewed with the aircraft operator. An initial scheme should be reviewed within no more than 6 months. If an existing scheme is being extended a longer period may be agreed.

A review gives you and the aircraft operator the opportunity to:

  • continue using a scheme;
  • make changes;
  • alter the scope of a scheme; or
  • stop using a scheme.

The aim of all reviews is to discuss with the aircraft operator whether the current scheme is producing the right amount of duty in a cost-effective way. If not, then what changes need to be made?

See auditing below for information about conducting reviews at the same time as audits.

Reviewing a scheme early

A scheme may be reviewed early in the following circumstances:

  • if the aircraft operator has not operated the scheme in accordance with the agreed conditions, or if incorrect data have been used;
  • the structure of the business changes (for example the timetable is changed); or
  • unforeseen circumstances arise which may affect the accuracy of the scheme (for example there is industrial action).

Note: Unless the aircraft operator agrees, a scheme cannot be reviewed early for any other reason. A shorter period should be agreed before the formal review if there are concerns about revenue risk in a particular case.


You should:

  • follow a systems-based, rather than transaction-based, approach to control for all schemes even if the schemes themselves are transaction-based;
  • not approve a scheme if you have reason to believe that it will be inauditable;
  • conduct audits and scheme reviews at the same time if at all possible.