Fiscal optimisation: Ryanair buys its 375 Boeing aircraft in … Luxembourg

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According to the Belgian newspaper “Echo”, the Irish low-cost airline Ryanair is buying its planes by a Luxembourg subsidiary funded by money from the Isle of Man.

While its planes do not take off Findel, the Irish low-cost airline is indeed very present in Luxembourg. Belgian newspaper L’Echo says that “it is through a company registered in the Grand Duchy that Ryanair ordered in less than two years the fleet which dominates the skies over Europe for years : 175 Boeing 737-800 in March 2013, and last September, all 200 of the new planes Max 200 series provided by the same US manufacturer.” For that bulk purchasing without equivalent, Ryanair negotiates preferential rates and secrets.

In addition to the subsidies paid by “its” European airports close to Luxembourg, Charleroi (Belgium), Frankfurt-Hahn (Germany), Ryanair also pocketed huge help for export from the United States because of its purchases from Boeing, its manufacturer of record. But the already wealthy Michael O’Leary, founder and boss of Ryanair, also knows how to do on tax optimization.

Until then, its planes were often purchased by companies located in the US state of Delaware, where the tax is zero for firms that do not have actual activity. The planes were quickly leased to Ryanair and the Irish Revenue never saw the color of money, “writes the newspaper” The Echo “.

Ryanair, which also has subsidiaries for tax purposes on the Isle of Man, Cyprus and Lithuania, is now also established in Luxembourg. On 18 January 2013, Ryanair Limited took control of a Luxembourg company, Acapulco Investments, bought from a Panamanian company. Acapulco is then became part of a trust company (Capita Fiduciary) whose parent company is British and managing director resident in Jersey. Five days after its purchase, Acapulco became Aviation Finance and Leasing in Luxembourg, with a branch of the same name in Switzerland. In early activity, the Luxembourg subsidiary of Ryanair worked with one part-time employee. Then two more later.

On September 8, 2014, Michael O’Leary has ordered 200 new Boeing of a type that he will be the first to use. This purchase will be explained to shareholders at an extraordinary general meeting, Friday, Nov. 28, in Dublin. “In the notice announcing the AGM, it is briefly described that a subsidiary 100% owned by Ryanair has agreed to make the purchase of a value of EUR 16.7 billion. The Aviation Finance and Leasing name is mentioned. But not its host country,” said” The Echo “.

This country is Luxembourg. AFL headquarters is located at 16, avenue Pasteur, in Luxembourg City. As in Delaware, the Boeing aircraft are purchased and leased back just as quickly. In the accounts of the Irish firm, leasing aircraft is charged in the form of operating expenses, thereby limiting the profit subject to tax. In Luxembourg, Aviation Finance and Leasing has no real activity. Just the opposite of the Ryanair Boeings crisscrossing the European sky without ever taking off from Findel.

After L’Echo and L’Essentiel