Doc 8632
ICAO'S POLICIES
ON TAXATION
IN THE FIELD OF
INTERNATIONAL AIR TRANSPORT
THIRD EDITION — 2000
Approved by the Council on 24 February 1999
Published by direction of the Council
INTERNATIONAL CIVIL AVIATION ORGANIZATION
ICAO'S POLICIES
ON TAXATION
IN THE FIELD OF
INTERNATIONAL AIR TRANSPORT
Doc 8632
Third Edition — 2000
(iii)
FOREWORD
After a comprehensive study of the various existing and anticipated problems related to taxation in
the field of international air transport, the Council in 1951 adopted 3 Resolutions and a Recommendation on
the subject which were published in Doc 7145-C/824. In response to Assembly Resolution A15-16 which
explored the possibility of a new initiative in this field the Council undertook a comprehensive review of all
aspects related to this subject matter and, at the Fourth Meeting of its 59th Session, on 14 November 1966,
decided to recast the Resolutions and the Recommendation, taking into account developments since 1951,
while reaffirming at the same time their underlying principles. The Council further decided to publish them
in the policy document, Doc 8632-C/968, for action by Contracting States and to provide certain explanatory
material for guidance to States and international operators.
The 1966 Resolutions/Recommendation dealt with:
i) taxation of fuel, lubricants and other consumable technical supplies when an aircraft registered in one
State arrives in or departs from a customs territory of another State;
ii) taxation of fuel, lubricants and other consumable technical supplies when an aircraft registered in one
State makes successive stops at two or more airports in one customs territory of another State;
iii) taxation of the income and aircraft of international air transport enterprises; and
iv) taxes related to the sale or use of international air transport.
The Assembly, at its 26th Session in 1986, adopted Resolution A26-15 which instructed the Council
to review compliance with these Resolutions and Recommendation and to consider the need for new practical
measures to reaffirm and strengthen the principles underlying its policies in this field. After consultation with
States the Council reported the results of its review to the 29th Session of the Assembly which agreed with
the Council's approach to the revision of the 1966 Resolutions and Recommendation, the results of which
were published in a second edition of this document in January 1994. The 29th Session of the Assembly also
reinforced the importance of this policy statement by adopting Resolution A29-18 which called upon States
to follow the Resolutions of the Council as contained in this document.
During the 1996 - 1998 triennium, the Council undertook a comprehensive review of the policies and
concluded that the four resolutions remain fundamentally sound but should be consolidated, without
substantive change, into a single resolution. The purpose of the consolidation would be to provide States and
other users with a shorter, transparent, and more useful and convenient presentation of the Organization’s
position on taxation. This approach was noted by the 32nd Session of the Assembly, which reflected the
thrust of Resolution A29-18 in a new Consolidated Statement of continuing ICAO policies in the air transport
field, Resolution A32-17 (Appendix E).
At the 3rd Meeting of its l56th Session, the Council adopted the consolidated Resolution on Taxation
of International Air Transport which appears in the present document. In adopting the consolidated
Resolution, the Council stressed that these policies on taxation would be reviewed and adjusted if at any time
the Organization’s present position on environmental charges and taxes (State letter AN 1/17.9-97/62 dated
11 June 1997) is changed in a way that could have implications for the policy.
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(v)
TABLE OF CONTENTS
Page
INTRODUCTION . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1
COUNCIL RESOLUTION ON TAXATION OF INTERNATIONAL AIR TRANSPORT . . . . . . 3
COMMENTARY ON COUNCIL RESOLUTION . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6
- - - - - - - - - - - -
INTRODUCTION
1. It has long been recognized that international air transport creates a number of special or unique
problems in the field of taxation. Taxation in the field of international air transport is a complex subject and
covers many aspects, considering the variety of items which may be subject to taxes and the types of taxes
that may be levied. Amongst the items which are usually taxable and have been considered in the past in
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