Air Passenger Duty ― records and returns

By Tolley

The following Value Added Tax guidance note by Tolley provides comprehensive and up to date tax information covering:

  • Air Passenger Duty ― records and returns
  • Records
  • Errors
  • Assessments
  • APD returns
  • Penalties

This guidance note provides an overview of the APD record keeping requirements, and also provides details on how to complete and submit an APD return. This note should be read in conjunction with Air Passenger Duty ― overview, APD ― registration and Air Passenger Duty ― annual accounting and special accounting scheme.


The following persons are required to keep APD records and accounts:

The Air Passenger Duty Regulations 1994 (SI 1994 No. 1738) (as amended); The Air Passenger Duty (Connected Flights) Order 1994 (SI 1994 No. 1821) (as amended); The Aircraft Operators (Accounts and Records) Regulations 1994, (SI 1994 No. 1737) (as amended); The Air Passenger Duty (Extended Schemes) Regulations 1995 (SI 1995 No. 1216); The Air Passenger Duty (Designated Region of the United Kingdom) Order 2001 (SI 2001 No. 808) (all subscription sensitive)Excise Notice 550 ; De Voil Indirect Tax Service V19.101 (subscription sensitive)
  • operators who operate a chargeable aircraft that is used to transport chargeable passengers
  • a fiscal representative acting on behalf of the operator
  • administrative representative who has been authorised by the operator

HMRC does not specify the location where the books and records need to be retained, but it does state that the operator, or their representative, must ensure that the books and records are available for inspection at the address where the operator is registered for APD. If HMRC intends to undertake an audit of the operator’s books and records, they will normally contact the operator to make an appointment, and, at this time, they will confirm the place where the records will be available (this is normally the place where the business registered for APD). HMRC should clarify which records will be required during the inspection when they arrange the visit. If

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