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Air Passenger Duty for 12+ hour flights to rise to fund domestic cuts – consultation

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The Government published a consultation paper yesterday on reforms to Air Passenger Duty. You can download it from this page of gov.uk.

The level of domestic Air Passenger Duty has become a political issue. When Flybe failed, one reason it gave was that the level of APD – £26 on a return domestic economy flight – was wrecking its economics.

It has also became a football in the UK ‘levelling up’ agenda. With most European countries not having any similar taxes, or not at the same level, it can be cheaper to fly to Munich than Manchester. You would only be paying the £13 economy Air Passenger Duty on the outbound flight rather than on both legs.

Few Governments have ever voluntarily cut stealth taxes, of course. Air Passenger Duty raised £3.6 billion in the 2019/20 tax year, and would have been higher had covid not cut into travel towards the end of the tax year.

As the consultation paper admits, it is also “easy to collect”.

What does the consultation paper suggest?

The Government is suggesting that:

  • domestic Air Passenger Duty be halved
  • Air Passenger Duty be increased on flights over 5,500 miles

There are two proposals for halving domestic APD

For some odd reason, the Government wants to debate two different ways of halving domestic Air Passenger Duty. One is totally stupid and one is blindingly obvious.

The stupid route is to make the return leg of a domestic flight ‘APD free’.

You can instantly see the problem here. If your domestic flight is booked as 2 x one-way flights, the full £26 of Air Passenger Duty will still need to be paid. Only a return booking on a single booking reference would qualify.

As the consultation admits, this would require both flights to be taken with the same carrier. It also screws passengers who only require a single trip or are returning by another mode of transport.

Another problem, not mentioned in the consultation, is that this is likely to reduce competition on domestic routes. Because booking return flights with the same carrier will be cheaper than two single tickets with different carriers, it makes sense for routes to become monopolies.

The sensible route, option two in the consultation, is to halve APD for domestic flights to £6.50 each way.

It is hard to believe that there is even going to be a discussion on which option is better.

The only quirk is that APD in Scotland is to be devolved to the Scottish Government, although this will not happen until agreement is reached on the ‘Highlands and Islands Exemption’.

How will APD increase for longer flights?

This is what you currently pay as Air Passenger Duty:

Air Passenger duty bands

As you can see, the cut-off is at 2,000 miles which is approximately a four hour flight. There is no distinction between, say, Tel Aviv and Tokyo.

There are two proposals for change:

  • Revert to the pre-2008 structure of bands at 2,000 miles, 4,000 miles and 6,000 miles
  • Create one additional band at 5,500 miles

The original pre-2008 scheme was scrapped because it created certain disparities. The banding is based on the distance between London and the capital city of the destination country. This meant that the US West Coast was in a low band, because Washington is on the East Coast.

The preferred choice in the consulation is for the 5,500 mile option. This would take in cities such as Tokyo, Cape Town, Mexico City and Bangkok. It would not include the US West Coast, even if the rules were changed to base it on the exact distance rather than the difference between capital cities.

How much would APD be for the 5,500+ mile band?

No indication is given.

How about a frequent flyer levy?

The consultation also suggests launching a frequent flyer lever.

This would require you to submit details of all of your annual flights to the Government. An additional tax bill would be generated based on your annual travel.

The Government is not keen on this option but it is part of the consultation.

What happens next?

The consultation is open until 14th June.

If you wish to make a submission, details are in the paper. You can download the consultation document here.

Comments (125)

This article is closed to new comments. Feel free to ask your question in the HfP forums.

  • BJ says:

    A nice article Rob, thanks for your time on it.

    In addition to the stupidity highlighted in the article I see two other huge elephants in the room. Firstly, the airlines will simply use any reduction in domestic APD to disguise fare hikes so the benefit will ultimately be to them, not the passengers or the country. Secondly, option 2 for 5500+ miles is only going to increase the popularity of exEU flights; I would certainly have no issues using APD to fund a night or two in say Amsterdam before a longhaul trip. For us, situation with INV remains key.

    Seriously hope we will not return to the dark days of booking return and staying a Saturday night because one way flights are no longer cost effective.

    • Tony says:

      Agree, have never bothered with exEU flights, but happy to stay a night in Amsterdam if APD becomes prohibitive. This will be damaging to many airlines, BA mainly, and UK airports. Amsterdam and Paris will be building a new terminal for us…

      • Chrisasaurus says:

        Airports not so much – how you gonna get to Amsterdam?

        • The real John says:

          Eurostar, although having done it several times I personally wouldn’t do it again unless price was very attractive.

          • Rhys says:

            Why?

          • Rob says:

            5 hours for a start ….

          • Genghis says:

            I’ve done Amsterdam once on Eurostar one way, St Pancras to Centraal. I thought the journey was quite pleasant and would do it again. The 1pm arrival time is convenient.

          • The real John says:

            Yes the long trip time really drags on and when the train is completely packed, as it used to be when they had £35 tickets, it isn’t very pleasant. Even a BA seat is more comfortable

            Also getting to St Pancras is a faff for me, and although the check in gates do let you through with 10 minutes to departure they say you should be there 30 mins early.

            Not sure if Amex still gives you lounge access but I don’t have the card

            If Rotterdam was my destination I would consider E* and BA from LCY equally

      • ChrisC says:

        In the scheme of things the number of people based in the UK doing ex-EUs is very small. Even if they doubled they would still be very small.

        For a lot of people they can be a faff and and that will put them off. There are plenty posts here saying things like “the partner won’t put up with doing this even though there are savings to me made” and “the thought of doing this with kids …”.

        And the savings aren’t really in APD. You’d end up spending more on positioning flights and hotels than what you’d save in APD

        The biggest savings are when BA is competing against the likes of KL and LH when they have sales and there can be some good deals. But they don’t exist all the time.

        And the best deals are mid week when fewer people want to to travel.

        I do do ex-EUs but I carefully price up the options and TBH more often than not they aren’t worth it because the savings just aren’t there once I’ve factored in positioning flights and more often than not a hotel at the ex-EU starting airport.

        • BuildBackBetter says:

          +1.
          It’s a minority who go thru the hassle of connections, hotels, transfers just to save a part of APD.

          • Lady London says:

            If the cost of ex-EU is close ( or even a bit more) then I’m flying ex-EU. Simply because it can be useful in other ways but mostly because flying is not luxury for me it’s essential and I’ll be d@rned if I will ever pay APD if I can avoid it.

          • PhatGit says:

            Those of us that live outside London already do, especially with continued “suspension” of BA regional connection flights. I have multiple daily options to CDN and AMS within a short drive of home.
            Even before BA cut the flight from LBA, timings were so poor that an overnight at LHR was needed on at least one direction.
            This would definitely be a strong option for us

        • BJ says:

          I was referring to HfPers in particular, not people in general. Unfortunately we have to live within the provisions for the masses. I was never a fan of exEU as I like to keep my journey time short but I did start using exINV in the last three years. However, if I can have a pleasant day and night in a European capital for less, or not much more than exUK I will not automatically turn my nose up at that opportunity.. It’s only faff if we make it faff.

        • Chris Heyes says:

          ChrisC Yes I agree the vast numbers won’t bother, but a few will, our holidays consist as a 3/4 week trip early Sep (as soon as BA off-peak kicks in) if long haul we almost always do “Open Jaw” flights different places to visit (we cant drive)
          short haul usually May/June off-peak 2/3 weeks and January/February although knocked Jan off recently, due to me always getting a cold on return
          But it could work for us ie 1 week short haul then fly off for 3 weeks long haul
          It’s something we haven’t tried but worth a thought ?

          • kitten says:

            You are correct @Chris H the gap needed after a short haul is only 24hrs 1 min to disqualify the following longhaul from apd. Might give you a worse priced fare class for the ticket though.

            Or, two tickets as now however then you have to allow more time between the flights as delay cushion, collecting luggage and re-checking in and not choose the last one of the day on the first flight in case you don’t make it out at all.

            Currently of course ex-EU is much more risky due to the constantly changing Covid landscape across countries as are flights that connect in a foreign hub so a short vacay shorthaul on the way out may be the way to go.

          • Chris Heyes says:

            Hi kitten, Price doesn’t matter to us we have never bought a cash ticket, so the only factor for us is tax and charges

        • Andrew says:

          “In the scheme of things the number of people based in the UK doing ex-EUs is very small.”

          It depends where you are starting from… if you are out in the sticks (ie not close to LHR) connecting via AMS or CDG is still less hassle than via LHR.

          Even allowing for a reduction in domestic APD…

          • Jonathan says:

            Needs to be separate tickets with all the implications that brings if you want to dodge longhaul APD going via. Amsterdam etc.

      • ChrisC says:

        Rob. Where dos you get 5 hours from?

        St Pancras to Centraal is 4 hours.

        Did you forget to allow for the time zones?

        • Rhys says:

          Journey time might only be 4 hours but you still have to arrive at little early etc

          • ChrisC says:

            Same with a flight though Rhys!

            There are check in times for both.

            On a flight when you arrive at AMS there is passport control to go through where other flights may have just have arrived so could be a long queue,

            Then getting off the train at Centraal there is no wait for luggage but at Schipol it’s never taken less than 30 mins for the bags to arrive.

          • Rhys says:

            I’m aware. In reality, I imagine by the time you are in the city centre the total journey times are probably roughly equal.

    • Chrisasaurus says:

      It may be absorbed but then if the Flybe argument is valid then for domestics it is needed to make the flights sustainable.

    • BuildBackBetter says:

      Don’t agree with first point. Are you saying effectively there should be no reduction in APD? Some people seem to wake up just to complain about something!
      Extending your argument, surely increase in APD in long haul shouldn’t make a difference as well?

  • Susan says:

    Cutting taxes on routes where there are viable, greener alternatives to aviation and increasing them on ones with no such option is baffling to me. It’s barking that flying to London from Edinburgh is cheaper than taking the train.

    • Tim Hewson says:

      Agreed. Manchester to London is just over 2 hours on the train, with no check -in time and a 20 minute frequency. From an environmental perspective flying that route is plain wrong APD of £200 would be fine with me. But if you want to connect with Australia, there is no alternative to flying, the environmental costs are offset against the benefits of connecting with friends and customers.

      • BJ says:

        Manchester to London domestic is on it’s last legs I think. Skeleton services might be retained fo r longhaul connecting pax only. I think this will actually do less harm than good, outcome is likely more direct flights to more places from Manchester. I am even happy to use the train from Edinburgh to London and have done so exclusively bow for the past five years. I just don’t see a need for Manchester to London point to point going forward.

        • Jonathan says:

          The problem with a skeleton service is it makes connections a PITA. KLM or LH is suddenly more attractive if it’s a 90 min change in AMS/FRA vs spending 4 hours at Heathrow.

          The biggest issue with domestic flights is the failure to include Heathrow as a stop or spur on HS2. That would have been a complete game changer.

        • Ken says:

          Not least because you have Stockport, Warrington & Runcorn all doing direct roughly 2 hours trains to London as well as Manchester.
          All close to motorways.

          Was APD the real reason for Flybe failing? Not really.
          An unwieldy model of 20 odd different airports, no Heathrow slots and not enough high yielding business passengers.

          • Andrew says:

            I definitely flew Flybe LHR to EDI.

            APD wasn’t helpful for marketing. Neither was the compensation paid on cancelled or delayed flights good for profitability.

          • Rob says:

            I reviewed one of the Flybe LHR services, may have been EDI.

    • John says:

      Absolutely. APD could be a really useful tool to drastically reduce or eliminate carbon-hungry flights on routes where they’re really not necessary.

      • Babyg says:

        yawn… APD to reduce carbon hungry flights? stupid idea. If its really an issue tackle the problem directly.

        • BJ says:

          So you prefer they just stop you from flying instead of charging you more to discourage you?

          • Babyg says:

            Correct, nothing encourages people to take the train more than having no other option.
            Increasing ADP wont stop the plane flying (these feeder flights etc will still run) all it will do is just generate more revenue for the government, so it simply hurts your wallet and does nothing for the environment. Have you EVER seen a major airport reduce flights long term (err ignore covid times) because a hike in taxes?? nope.

    • memesweeper says:

      “It’s barking that flying to London from Edinburgh is cheaper than taking the train.“

      It may seem so, but there are also plenty of very cheap fares EDI-LON on the train too, probably equal or less than APD. The issue is peaks/capacity, as well as price/choice on routes like this. The cost is the infrastructure and macro-level running costs — the Advanced Ticket price is just a demand/yield management tool these days, it bears no relationship to the cost of providing the service on trains.

      • BJ says:

        I’ve been using 1p Nectar on First Advance for a few years. Great while it lasted. Much more pleasant than flying.

    • BJ says:

      Sleeper not work for you?

      • Andrew says:

        Check the prices of the sleeper. The London arrival time isn’t ideal for an 07:30 start in Oxford either.

        (I can do the return journey for £80 in diesel. And when I borrowed a mate’s Tesla – approximately £25 in electricity.)

        • BJ says:

          Up for car share @Alan? I could use yours while you’re at work in Edinburgh 🙂

    • BuildBackBetter says:

      Train is the wrong comparison. How many families, especially those with kids take train?
      The real comparison should be with cars.

    • Lady London says:

      Plus one car will carry a whole family. Instead of paying literally, factually the world’s highest train fares, for each person.

  • C says:

    The frequent flyer levy is bonkers. Think of the administrative burden of collecting and monitoring everyone’s flight details. Of course, what with exit clearances (aka lockdown exceptions) not far off, perhaps not so far fetched. Soon we’ll see it as normal to be required to request permission to leave the country, after submitting details of flights, accommodation, persons being visited, and paying exit taxes and return isolation waiver fees in advance.

    • Andrew says:

      Ah yes. UK passport to Dublin. Irish Passport for long haul.

    • Yorkieflyer says:

      And this is the worry, government never likes removing tax and regulations.

  • Erico1875 says:

    Going forward, electric planes for domestic routes should be the only option if flying
    Cant be that far away now, can it?

    • Andrew says:

      I don’t see the point of an Electric plane if I can’t make the same full journey on an electric train.

      • memesweeper says:

        Guess you’ve never wanted to travel to/from Belfast then? Your wait for the train could be a long one.

        • Andrew says:

          Well, the Scottish Government’s farce with electric ferries has probably killed that market for quite some time.

    • memesweeper says:

      Should be feasible… but the market for short-hop planes is niche. Outside of highlands/islands most domestic flights in the UK are made with A320s/737s/Dash-8s/E-190s… all capable of longer distances than merely UK domestic, and longer than electric is likely to be capable of in the next few years.

      I think it might be drones or something similar that kills it for fossil fuel domestic flying (and indeed non-commuter trains).

      • Rich says:

        I think they were talking about a small commercial aircraft with 500km range within 10 years.

        The market that instantly sprang to mind was Greece domestic. Everywhere is within 500km of ATH and slow to get to by surface.

        Rapid charging an aircraft on Kalymnos might scupper it though!

    • BJ says:

      Westray to PapaW coming soon 🙂

  • TT says:

    The UK government: we must expand Heathrow, flying helps make us competitive.
    Also the UK government: flying is bad, you must be taxed for your sinful behaviour. If we really believed that, shouldn’t we charge connecting passengers who take 2 flights vs our one direct? Seems nonsense that we let someone flying from Amsterdam via London pay less than we do

    • AJA says:

      That’s the dilemma though, environmentally flying is bad unless all aeroplanes are packed to the gills and are the latest versions but at the same time expanding Heathrow is good for business in this globally connected 24 hour per day trading. Government has this dilemma all the time – promoting arms sales is bad for people who are killed by them but good for UK arms manufacturers.

      The reality is that APD is an easy money raising venture for the government and the environmental lobby love it as a means of discouraging us from flying while the frequent fliers here hate the idea.

      The thing with your scenario of flying from AMS via LON to XXX is that it is a UK departure tax and provided you only connect in London you are not deemed to be departing from London if the connection in London is less than 24 hours. It’s fair as you don’t actually enter the UK staying airside for the connection.

      The issue with charging lower UK APD for domestic flights is that it supports airlines but discriminates against train operators. It also makes those positioning flights to INV more affordable which is less environmentally acceptable.

      • The real John says:

        If not entering the UK is the criteria then the 24 hours should be reduced. When doing an ex-EU I always do the AMS as a day trip then go home to sleep and return for the long haul the next day. Though the savings mainly come from the fares not the APD

      • Rich says:

        Why not charge transit passengers though? It would be easy to do, and if the aim is to reduce flying, why should the burden fall on UK departures?

        If some of these routes are so fragile that we need transit passengers to keep them going AND we need to give them a tax break to do so, maybe those routes don’t need to exist.

  • Ben says:

    I believe APD is already devolved to Scotland. Nicola sturgeon has already said she has no intention of reducing it too.

    • Mark says:

      The situation in Scotland will also be influenced by the Green Party if they are required to help the SNP form a government.

  • Stuart says:

    Why not change APD to VAT?

    • memesweeper says:

      Possibly restricted by treaty.

      Definitely bad for business for British airlines if they need to start charging international origin/transit passengers VAT on the ticket price. APD is UK origin only.

    • sigma421 says:

      You can definitely levy VAT on wholly domestic flights within an EU country. Spain does.

    • Chrisasaurus says:

      Because business don’t get to reclaim APD…

  • Matarredonda says:

    Am I correct in thinking fuel for aircraft is free of tax? If so add VAT to fuel for domestic routes and then leave to market forces to price the flight cost.

    • Rantallion says:

      The airline recovers the VAT so no tax revenue is raised.

    • Andrew says:

      I’m not sure how often planes are refuelled.

      But, won’t that simply result in diagramming routes to low-tax countries and carrying more fuel than necessary?

    • marcw says:

      Aviation is probably the most “subsidised” industry. No tax on jet-fuel, no tax on plane purchases/leases, no VAT on tickets…

      • Chris says:

        How much tax is on a domestic train fare? Or bus fare?

      • ChrisC says:

        There is an arument to be made that APD replaces any and all of those taxes.

      • Paul Pogba says:

        Unlike the railway which will receive £22bn from central government in 2021, and required £14.5bn in 2019 before demand collapsed.

    • the_real_a says:

      Tax isnt charged because airlines would just “tanker” fuel from destination countries not charging tax – it would be counter productive as you would also see empty planes making special flights to fill up fuel in third countries.

      • memesweeper says:

        Indeed they likely would … if you tax sales of fuel as you do petrol or diesel.

        An alternative would be to tax fossil fuel burned on take off and the first X hours of flight. Accurate estimates of these numbers are widely available. It would incentivise full planes, biofuels, electrification and efficient aircraft. It would not AFAIK breach the treaty agreements not to tax fuel on sale or importation (in the tanks of planes landing internationally). Unlike APD, foreign connecting passengers would see some impact — so some disadvantage for British airlines versus foreign competitors — but if the UK adopted it my hunch is every major European nation adopting the same model very quickly and the ex-EU tax dodge would vanish.

        • The real John says:

          ex-EU is mainly for cheaper fares not to reduce APD.

          I would just tax the slots with some form of carbon tax based on size and emissions of the plane, it should not be a passenger tax.

          As is often argued, the plane would often be flying anyway and one extra bum is only marginally more harmful. This would encourage airlines to minimise the cost and thus the pollution per passenger.

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