Martyn Fiddler update – January 2025

Keeping ahead of the latest regulatory, legal and policy movements is part of what we do. Here are the latest updates from our team.

Martyn Fiddler update – January 2025

15 Jan 2025

Keeping ahead of the latest regulatory, legal and policy movements is part of what we do. Here are the latest updates from our team:

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.

Stay tuned for updates from our Tax, Client Services and Accounts team next week! 

If you want to see more from Martyn Fiddler, please follow us on linkedin: Martyn Fiddler

LinkedIn

Follow us on LinkedIn to stay up to date with all our latest news and events.

YouTube

Subscribe to our channel to watch our webinar series and IOM Aviation Conference videos.

Related posts

CJI London 2025: THE business aviation conference

2025 02 06 All News

It is difficult to write a fitting introduction for the best business aviation conference of the year! 60 hours of networking, discussions, learning, debating, sharing, laughing and perhaps...
What if…The UK rejoined the EU Customs Union?

2025 01 30 All News

Given the recent headlines regarding the possibility of the United Kingdom rejoining the European Union Customs Union, we thought it would be fun to speculate what this would mean for business...
Martyn Fiddler January Update – Part 2

2025 01 23 All News

Keeping ahead of the latest regulatory, legal and policy movements is part of what we do. Here is part 2 of the latest updates from our team.

UPDATES

Sign up for our newsletter

Get our latest updates an event notifications