1. Application of the Solidarity Tax (TS) for Corsican Airports
1.a. What is the legal regime for the solidarity rate of the tax on air passenger transport for Corsican airports?
The solidarity tax (TS) applies based on specific criteria, including taxable items and taxable events, as follows:

The TS applies to any commercial flight departing from national territory, which includes metropolitan France, Corsica, and overseas departments and regions.
The taxable event for the TS is the passenger’s boarding, as stated in article L. 422-14 of the Goods and Services Tax Code (CIBS).
For domestic flights (e.g., Marseille – Bastia), the TS is only paid once.

1.b. What is the link between the tax referred to in article L. 422-29 of the CIBS and the TS for Corsican airports?
In Corsica, the tax related to boarding or landing falls under article L. 422-29 and represents a surcharge on the Tax on Air Passenger Transport (TTAP). This surcharge is separate from the TS and does not impact its application.

2. TS Liability for Helicopter Operators
Are helicopter operators liable to pay the TS for passengers on board commercial flights?
Yes. Under article L. 422-14 of the CIBS, any passenger boarding in the taxable territory on a commercial flight, except in direct transit, is subject to the TS.

Helicopters are classified as aircraft under article L. 6100-1 of the French Transport Code.
As a result, commercial helicopter flights fall within the scope of the TS, regardless of the aircraft type used.
This applies under existing legislation, which makes no distinction between different aircraft types for commercial flights.

3. TS Rate for Non-Scheduled Helicopter Services
Should helicopter operators providing non-scheduled air services apply the “business aircraft – turboprop” rate or the general commercial rate?
According to article 30 of the 2025 Finance Act:

Only operators of non-scheduled air services using aircraft equipped with one or more turboprops are subject to the “business with turboprop” rate.
Since helicopters are not explicitly mentioned in article 30, helicopter operators providing non-scheduled air services (just like those providing scheduled services) must apply the tax rates corresponding to the following service categories:
“Normal”
“With additional services”
The rates must be applied in accordance with the TTAP tax base (see Question 2).
4. TS Exemptions for Employees or Managers on Board
Is the TS due when an employee or manager of the operator (who is not a crew member) boards a flight on behalf of the company?
According to article L. 422-14 of the CIBS, any passenger boarding a commercial aircraft in the tax territory, except in direct transit, is subject to the TS.

However, exemptions apply:

TS is due if an employee or manager boards for personal reasons (e.g., a flight attendant traveling for vacation).
TS is not due if an employee or manager boards for professional reasons (e.g., a crew member repositioning for duty).
Additionally, for private flights (own-account transport) involving:

Employees or managers of the operator, or
Employees or managers of a company that owns 100% of the operator,
These flights are not subject to the TS.

5. TS Exemptions for Emergency Medical Flights
Do emergency medical evacuation flights qualify for TS exemptions?
Yes. According to the 2025 tax notice, the following are not considered public air transport flights:

Emergency medical evacuations, including round-trip flights for vital transport of blood, organs, or medicines.
This means:

Any medical flight for a vital emergency (transporting a patient, organs, or medicines) is exempt from the TS.
Return flights or empty positioning flights (even if not urgent) but part of the same medical operation are also exempt.
6. TS Application to General Aviation and Private Transport
Is the TS due when an aircraft is not specifically operated on a commercial basis, and the flight plan is filed as “General Aviation” (G)?
Flight plans specify the type of flight, such as:

G – General aviation
N – Non-scheduled transport
R – Scheduled transport
M – Military
X – Other
However, filing a flight plan under “General Aviation” (G) does not determine whether the tax applies.

Article L. 422-5 of the CIBS defines commercial flights based on economic activity and passenger transport for third parties.
If an aircraft is not used for commercial transport, the flight is not taxable under the TS.
How does fractional ownership affect the TS?
Shared or fractional ownership models fall under own-account transport (not commercial).
If no economic activity is involved, TS does not apply.
However, if a specific case indicates commercial transport, the TS may be due.
For detailed interpretations, refer to the DGAC notice on shared/fractional ownership:
DGAC Transport Guidelines

7. Impact of Flight Plan Filing on TS Application
Does the flight type in the flight plan affect TS liability?
No. The TS applies based on whether the flight meets commercial transport criteria, regardless of flight plan type (G, N, R, etc.).

8. TS for Passengers Who Are Also Shareholders
Is an operator liable for the TS when a shareholder boards as a passenger?
Yes. If:

The operator operates a commercial flight under article L. 422-5, and
The shareholder qualifies as a passenger under article L. 422-3,
Then the TS is due for their boarding.

9. TS for Aircraft Configurations with 19+ Seats
How is the tax applied to aircraft with a maximum operating seating capacity (MOPSC) over 19 seats but configured for 19 seats or fewer?
For example:

A318 ACJ

Boeing 737 BBJ

Article L. 422-22-1 of the CIBS (created by article 30 of the 2025 Finance Act) refers explicitly to MOPSC, defined by EASA.

The tax category is based on the MOPSC value, not the seating configuration.

Aircraft classified under MOPSC > 19 seats must pay the higher tax rate.

10. TS Application for Multi-Stop Domestic Flights
What happens if a domestic multi-stop flight has layovers under 24 hours?
Under article L. 422-7 of the CIBS, a passenger is considered in transit if:

The journey is part of an air transport operation.
The final destination and initial departure airport are different (except for the Paris airport system: CDG, Orly, Le Bourget).
The layover is under 24 hours.