'Delivering Scotland's Air Departure Tax': consultation analysis report

4. Analysis Part B – Private Jet Supplement

Part B of the consultation document focused on the scope and operation of the Private Jet Supplement. These sections introduced and set out the following:

• User base and response
• Decarbonisation of the private jet sector
• Considerations for rate-setting

Question B1: Who are the primary users of private jets departing from Scottish Airports?

29 respondents answered Question B1. Only one private jet operator responded to the consultation.

High-Net-Worth Tourists

The majority of respondents who answered Question B1 said that a small number of wealthy individuals were the primary users of private jets. Many of the responses that cited the super-rich as primary users did not include a reason for travel. However, business reasons were often listed separately, indicating that the primary reason for high-net-worth individuals to travel on private jets is for leisure and tourism.

“There is also a demand for private jets by the luxury travel trade market, including people visiting for country sports, private whisky tastings and tours, and private stays in castles, lodges and estates.” - Scottish Tourism Alliance

Business Use

The other main reason recorded for private jet use was for those attending business meetings and exploring high-yielding investment opportunities.

“There is business aviation, usually defined as use of private, smaller, lighter aircraft, for business purposes that are high-yielding and/or time-sensitive business activities, including meetings of high-economic importance with investors or clients.” - Airports UK

Private Jet Flights for Important Services

Three responses wrote that private jets may be used for urgent flights where scheduled routes are unavailable or the timings are unsuitable. These included emergency medical flights, urgent cargo, and time-sensitive commercial travel.

Sports and Entertainment

Multiple respondents noted that Scottish golf courses and tournaments, along with other sporting events, attract significant numbers of sports professionals and celebrities who travel to Scotland by private jets. A similar number of respondents also wrote that celebrities, such as musicians and actors, are users of private jets flights to and from Scottish airports.

Other

Three respondents included Government ministers and politicians as private jet users. One respondent included the military as using private jets and another individual noted that “the Royal Family have flown on their private jet fairly regularly.”

Private Jet Ownership

Oxfam Scotland submitted evidence on the commonality of fractional ownership of private jets and cited that total and fractional owners combined make up only 0.0008% of the global population.

Scottish Government Response

The Scottish Government recognises that private aviation can facilitate business travel as well as support the operations of sporting and cultural events in Scotland. At the same time, the Scottish Government acknowledges that private jet travel provides a distinct service offering, characterised by a level of flexibility, privacy and convenience that differs from services available through scheduled commercial aviation. Given the higher costs generally associated with private jet services, their use appears to be concentrated among individuals with greater financial resources.

Revenue Scotland has begun a process of engagement with business jet operators in advance of ADT becoming operational from 1 April 2027, to better understand the market, systems and processes in order to aid in the administration of the tax.

The Scottish Government can also confirm that aircraft used for military flights, emergency medical service, search and rescue, fire-fighting flights, training flights and research flights will be exempt from ADT.

Question B2: What are the primary reasons for using private jets?

27 respondents answered Question B2.

Convenience and Route Flexibility

The majority of correspondents who answered Question B2 (19 out of 27) cited convenience as a reason for using private jets.

Time efficiency was highlighted as a reason for users to choose private jet travel. Respondents who specified how time was saved listed the ability to bypass security and immigration lines, ease of transfer, being chauffeured to and from the jet and the ability to use smaller airports to land closer to their destination.

Route flexibility was also mentioned, as private jets can be scheduled for convenient times, fly to airports/destinations not served by scheduled flights and can undertake multi-stop journeys. This customisability was regarded as a significant appeal for private jet users.

However, it was noted by Possible that “a sizeable proportion of private flights ... are often to leisure destinations which are well served by standard passenger flights, not to mention good train services.”

Privacy and Security

Six respondents expressed the importance of security for some private jet users, including the privacy benefits due to avoiding crowds and enabling anonymity.

Comfort

Five respondents also mentioned the luxury and comfort associated with private jet travel as a primary reason for usage.

Prestige

Two respondents listed prestige or status as reasons for private jet usage.

Purposes of Private Jet Travel

Business

Multiple respondents specified business trips as the primary reason for using private jets, as the scheduling flexibility allows for convenient travel to time-sensitive business meetings. It was noted by the Air Charter Association that a regional UK airport reported 80% of their private jet departures were for business purposes over a six-month period.

However, it was noted by three eNGOs that many leisure flights may be misrepresented as business flights. Responses referenced seasonal analysis by Possible that found that destinations for private jets from the UK heavily correlate with commercial flights’ leisure destinations, with the popularity of European Alpine destinations spiking in the winter and Mediterranean destinations rising in the summer.

Short-Distance Leisure Trips

Four respondents stated that private jets are often used for short- distance leisure trips, primarily to European and Mediterranean destinations. Three eNGOs expressed the view that these leisure trips encompassed a large percentage of private jet usage, citing research carried out by Possible and T3. The Air Charter Association did not share this view, writing that only “a small number [of flights are] for tourism/leisure purposes.”

Other

Two respondents included attending golf tournaments and transporting weapons for shooting parties as incentives for private jet usage.

Other reasons from singular responses for private jet usage were the transportation of pets, engineers and for refuelling.

Scottish Government Response

The Scottish Government is grateful to the respondents for their responses around private jet passenger base and reasons for usage.

While various reasons were submitted by respondents, private jet usage appears in part to be motivated by economisation of time and route flexibility, with private jets allowing passengers to complete journeys quicker than those flying on commercial airlines.

Question B3: What evidence can you provide about demand, profitability and price sensitivity of the private jet sector of Scotland?

26 respondents answered Question B3. Nine respondents said that they had no evidence or that evidence was not available.

Two responses discussed the increase demand for private jets coinciding with sport tournaments, such as the Open Championship. As this incentive is set out in previous analysis of responses, the impact of sports tourism is not set out in detail here.

Similarly, comments that included suggestions for rates and demand management proposals are set out in Questions B4 and B5.

Demand

Some respondents noted that private jet usage has risen significantly post-pandemic.

“From 2019 to 2023, growth trends have been observed for jet numbers (6.45% per year), distance travelled (11.31% per year) and emissions (9.93% per year) (Gossling, 2024). Various news articles also point to the sector being increasingly successful.” - Aviation Environment Federation

Demand Leakage

Multiple other respondents pointed out the mobile nature of private jet demand, suggesting that the aircraft might simply be moved out of Scottish airports, meaning aircraft emissions would be displaced rather than reduced, and tax revenue lost.

“[T]here is also a risk that higher taxation could displace activity to airports outside Scotland, particularly given the availability of alternative UK departure points within short travel distances. This would reduce Scottish economic activity without necessarily reducing overall private jet usage.” - Individual

Profitability

Multiple respondents agreed that profitability in the private jet industry is high with operators being able to pass any additional costs on to customers. It was also noted that taxation on private jets typically makes up a very small percentage of the average cost of a flight, which should easily be absorbed by the customers.

However, the only private jet operator to respond disagreed, citing the recent failures of over 13 UK private jet operators in the last 10 years and writing that “this gives a clear indication of the limited profitability in the market” (Air Charter Association).

Price Sensitivity: Inelastic

The majority of responses agreed that private jet demand is relatively inelastic due to the level of wealth across the customer base. Respondents note that the costs of operating a private jet are already very high and any tax increase would be similar to normal price fluctuations. Many respondents noted the low level of aviation tax burden for private jet flights, despite their users’ relatively greater financial means.

“The private jet sector operates on a low-volume, high-cost model and serves a niche market. Demand is relatively inelastic compared to commercial aviation, particularly among high-net-worth individuals and corporate users, although discretionary leisure use may be more price-sensitive." - Individual

Price Sensitivity: Elastic

Three respondents suggested that private jet usage for leisure and tourism may be more elastic than business users, with two of the respondents also suggesting that demand for corporate trips is sensitive to cost.

“Profitability and price sensitivity are key concerns in the industry. Clients have become increasingly price sensitive and the market is highly competitive which keeps margins low.” - Air Charter Association

Scottish Government Response

The Scottish Government notes that there are conflicting views from respondents about demand, profitability and price sensitivity of the private jet sector of Scotland.

Question B4: What role could ADT play in supporting decarbonisation of the private jet sector?

31 respondents answered Question B4. Five respondents wrote that ADT could play no role in supporting decarbonisation of the private jet sector with no further explanation.

ADT is a tax on flights made by aircraft fuelled by kerosine. Responses discussing Sustainable Aviation Fuels (SAF) or other alternate methods of taxation are not set out in detail.

Limited Scope for Decarbonisation

Multiple respondents expressed the view that the private jet sector remains extremely resistant to decarbonisation and ADT has limited ability to encourage the uptake of more efficient technology. Respondents suggested that ADT on its own will be unable to effect change and must be supplemented by other policies to reduce emissions.

“The scope for ADT alone to drive meaningful decarbonisation in the private jet sector is limited. Taxation may influence marginal behaviour at the edges of discretionary use but is unlikely to deliver technological or fuel-based emissions reductions on its own.” - Individual

However, the Air Charter Association notes that “a huge amount of work is taking place (and has for many years) to improve efficiency of aircraft and to transition to zero emission aircraft” within the private jet sector.

Private jet demand management

The most frequent suggestion for supporting the decarbonisation of private jet travel was increased rates of ADT. This is on the basis that substantially increasing the tax burden on private jets will see a decline in demand and corresponding reductions in emissions.

Many respondents further emphasised that the rate needs to be sufficiently high in order to see behavioural response. Four responses cited Oxfam Scotland’s analysis that a rate at least 10 times higher than the current rate under APD would be needed to curb private jet demand.

“We support a significant increase beyond the current higher rate of APD due to the highly inelastic demand of the sector. This price inelasticity necessitates large increases in taxation if any behaviour change is to be achieved. Prompting a shift from private jet flights via taxation is feasible as typically private jet routes have a viable commercial alternative.” - Aviation Environment Federation

However, the Air Charter Association disagrees with the logic of demand management, noting that “as a per passenger tax this directly encourages lower passenger loads on business jets” and potentially results in lost revenue with no impact on emissions.

Hypothecation

Multiple respondents also highlighted that the hypothecation of revenue from ADT for environmental initiatives could support the decarbonisation of the private jet sector. Respondents suggested that hypothecation would be in-line with the Scottish Government’s polluter-pays principle and the High-Level Principles for ADT published in 2025. Respondents included investment in sustainable aviation (including SAFs), alternative emission-friendly transport development and environmental project funding as potential areas for spending hypothecated tax revenues.

“There is the potential for a proportion of the monies raised from the ADT to support decarbonisation of the private jet sector, along with improving the reliability, frequency and quality of other modes of transport connectivity like trains to encourage other ways of travelling.” - Scottish Tourism Alliance

Tax Treatment of Emissions-Friendly Aircraft and Fuels

Multiple respondents expressed the view that, although ADT in isolation can do little to encourage decarbonisation of the private jet sector, incentives embedded within the tax to invest in emission-friendly technology can support long-term decarbonisation.

“ADT can reinforce the polluter-pays principle, signal behavioural change and encourage uptake of sustainable aviation fuels if future differentiation is introduced. ADT alone will not drive decarbonisation but can complement regulatory and technological measures.” - ZetTrans

Exemptions or reduced rates for electric and zero-emission planes to encourage the investment in and development of such technology was suggested by multiple respondents. The private jet sector was noted to be particularly suited to the trial of electric planes due to the small size of many private jets.

“... private jet flights tend to be carrying much smaller numbers of passengers shorter distances than commercial flights, these flights would be ideal candidates for electrification, as electric planes will be small and able to cover only short distances with small numbers of passengers for the foreseeable future.” - Possible

Some respondents proposed different rates or exemptions for aircraft that use SAFs. One respondent also suggested higher rates for older aircraft to incentivise the uptake of newer, more efficient planes.

However, some respondents noted that SAFs, electric planes and other emissions-friendly technologies are currently unable to be produced or implemented in any meaningful capacity. Other respondents simply expressed the view that nothing other than extreme financial pressure from a very high tax burden could produce any decarbonisation incentives and one individual wrote that even then “people will still be able to afford it.”

Ghost Flights

One respondent noted the high frequency of low occupancy or empty ‘ghost’ flights in the private sector. The respondent emphasised that these ghost flights must be addressed in order to successfully decarbonise the private jet sector.

“A report commissioned by the European Business Aviation Association, estimated occupancy at 4.7 passengers per jet, a figure often cited by the sector. This did not take into account the ~41% of private jet flights that are empty leg flights with an occupancy of 0.” - Aviation Environment Federation

Other

Some respondents queried why the Private Jet Supplement is set to be implemented in April 2028 instead of alongside the introduction of ADT in April 2027.

Scottish Government Response

The Scottish Government notes the wide array of views offered by consultation respondents on what role ADT could play in supporting decarbonisation of the private jet sector.

Hypothecation is not a typical feature of the Scottish tax system. Spending priorities are set out at the Scottish Budget and are not ordinarily explicitly linked to how revenue is raised.

The Scottish Government notes the points raised in relation to private jet ghost flights. ADT is a tax on the carriage of passengers, and the Scottish Government does not currently have the powers to tax flights that are not carrying any passengers.

Question B5: What additional factors should the Scottish Government consider in setting future ADT rates for private jet flights?

33 respondents answered Question B5.

Responses that discussed demand suppression through higher rates are not set out in detail, as the information has already been set out in the analysis of Question B4.

Equity

Several respondents expressed the view that higher taxation of private jets will encourage a greater feeling of fairness and equitable treatment in Scotland. It was highlighted that private jet users are significantly wealthier and produce significantly more emissions than economy class passengers, yet they pay proportionally far less in aviation taxes. Respondents also noted that increasing taxation on private jets is consistent with other Scottish Government policies and principles, including the ‘polluter pays’ principle.

“A key issue with private jets is that in a world where we have a limited carbon budget, this budget is being blown on a very small number of wealthy individuals, rather than benefiting much larger numbers of less wealthy travellers if we instead prioritised more efficient modes of transport.” - Safe Landing

In addition, two respondents suggested that the rate of the Private Jet Supplement should increase over time.

Demand Leakage and Scottish Economy Impact

Multiple respondents expressed concerns regarding potential demand leakage from Scotland to other UK airports. Respondents emphasised the highly competitive nature of the private jet sector and operators may simply move their aircraft elsewhere.

“Ultimately aviation is a movable resource and travellers, operators and owners have the option to move where they invest, travel from etc.” - Air Charter Association

Respondents also noted the negative economic impact that such demand suppression and/or leakage could have on the Scottish economy. Multiple responses emphasised the importance of high-net-worth individuals who arrive in Scotland on private jets and the loss of their financial contributions to local economies could be sizeable.

It was also noted that Scottish Government revenue from private jet taxation may also decrease if higher rates are implemented due to demand suppression and leakage.

A small number of individuals expressed the view that ADT and the Private Jet Supplement should simply be abolished.

“There should be no ADT for private flights or any other flights. We should grow the economy, not constrict growth.” – Individual

Administrative Simplicity

Some respondents highlighted the need for simple and clear administration of the tax with appropriate guidance and engagement with industry.

Definition of Private Jet

Concerns were raised by some respondents that the current definition of a private jet (‘special category aircraft’) in connection with the ADT special rate (Private Jet Supplement) will not capture all private aviation. The size and maximum take-off weight (MTOW) were highlighted as requiring adjustment, with some respondents indicating that “significant” (Aviation Environment Federation) proportions of private jet passengers will not currently be subject to ADT.

Hypothecation

Multiple respondents raised the possibility of hypothecation of the Private Jet Supplement revenue. Suggested beneficiaries of this hypothecation included environmental initiatives, including investing in green public transport, and making all public transport more accessible and lower cost. It was also noted that the revenue from the Private Jet Supplement could facilitate rate cuts or reforms to ADT to incentivise commercial connectivity.

Popularity

Several respondents (all eNGOs) raised the point that increased taxation of private jets is known to be a popular policy amongst the general public. Multiple different UK-wide research projects were cited to evidence the popularity of private jet taxation, including Survation and More In Common.

“Banning private jets, and higher rates of tax for frequent flyers and those that fly further have been key recommendations for the aviation sector provided by numerous Citizens’ Assemblies on climate change, including in the UK, Scotland and France.” - Safe Landing

Implementation Timeline

Similarly to Question B5, concerns were raised around the implementation of the Private Jet Supplement in April 2028 instead of April 2027 in the first year of ADT.

“We do not support this delay. While we understand the Scottish Government’s stated desire to ‘provide certainty and stability for taxpayers, passengers and the aviation sector’ by matching UK Government APD rates and bands for the first year of ADT’s operation (tax year 2027-28), we do not believe this should apply to private jets.” - Oxfam Scotland

Alternative Tax Systems

These suggestions are not set out in detail as they are outside the remit of ADT.

Multiple respondents raised the potential of a Frequent Flyer Levy to tackle private jet flights with few passengers and target those most responsible for carbon emissions.

It was also suggested that a ban on kerosene-powered private jets should be introduced to encourage the transition to zero-carbon and electric jets.

“To ensure that the private jet industry is sustainable, from 2030 onwards, only zero-carbon private flights (such as battery powered flights) should be allowed. Before 2030, additional taxes should be raised on private flights, with the exception of private flights that have a social or safety maintenance purpose (such as essential medical supplies.” - Safe Landing

Other suggestions included charging VAT on private flights, introducing a tax on landing and departure slots and changes to fuel duty (including specifically for private jet fuel).

Scottish Government Response

The Scottish Government notes the views of some respondents that taxation of private jet flights should be more proportional to total private jet operating costs, relative to the taxation of commercial aviation. As such, and in line with the principle that higher rates of tax should be paid by those who choose to travel on private jets, we will bring forward a Private Jet Supplement within ADT in 2028-29. All ADT rates for 2028-29 – including rates for private jet flights – will be set out as part of the 2027-28 Scottish Budget.

The Scottish Government has no plans to introduce a frequent flyer levy. A frequent flyer levy would be significantly more complex to administer than ADT, for both air carriers and Revenue Scotland, on the basis that it could require the tax authority to collect and store personal information on each individual passenger.

A frequent flyer levy may also pose concerns around data processing, handling and privacy. There may be additional compliance issues, particularly with passengers who were able to travel under multiple passports, as well as for passengers travelling from airports outside of Scotland.

Additionally, the Scotland Act 2016 devolved to the Scottish Parliament the power to create a tax charged specifically on “the carriage of passengers by air from airports in Scotland”, rather than a tax on passengers directly. The proposals for a frequent flyer levy and for a tax on landing and departure slots are out-with devolved competence and are not matters that the Scottish Government currently has the powers to pursue.

In addition, VAT and fuel duty are reserved to the UK Government. Proposals relating to these are not matters the Scottish Government has the power to take forward at this time.

To provide certainty and stability for industry and taxpayers, the Scottish Government has committed to matching the UK Government’s APD rates and bands for tax year 2027-28. This includes replicating the UK Government’s proposed updated definition of private jets.