Russia's flagship airline Aeroflot livery on an Airbus A320-200. Reuters
Russia's flagship airline Aeroflot livery on an Airbus A320-200. Reuters
Russia's flagship airline Aeroflot livery on an Airbus A320-200. Reuters
Russia's flagship airline Aeroflot livery on an Airbus A320-200. Reuters

Jet lessors face 'significant' challenges from Russia sanctions, Fitch says


Deena Kamel
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Global jet lessors are not yet affected by the Russia-Ukraine conflict and ensuing sanctions, but they face “significant” logistical and operational challenges as repossession of aircraft in Russia could prove more difficult, Fitch said.

Fitch-rated global aircraft lessors could also see negative ratings implications from a prolonged ban on conducting business with Russia and the secondary global macroeconomic effects resulting from the conflict, the credit rating agency said in a research note on March 4.

“The direct effects from expanded economic sanctions imposed upon Russia, including the European Commission's requirement that aircraft lessors terminate existing lease agreements with Russian airlines by March 28, should not materially pressure lessors' net margins, liquidity coverage levels or cash flows over the 12-24 month outlook horizon,” Fitch said.

“However, potential disruptions from indirect effects of the conflict on the broader aviation and airline sector outlook remain in flux and uncertain.”

Plane-leasing firms, many of which are based in Ireland, are seeking possession of the aircraft by March 28 under EU sanctions and a broader set of banking restrictions that make it impossible to legally continue renting and insuring the aircraft to Russian customers.

Lessors have “sufficient rating headroom and liquidity” to manage the impact of the sanctions, given relatively low exposure to Russian airlines, diverse customer bases and solid cash flows generated from long-term leases, Fitch said.

As of January 31, 2022, exposure of Fitch-rated lessors to Russian airlines ranged from 0 per cent to 10 per cent of net book value, according to Cirium.

More than half of the active commercial aircraft fleet based in Russia are leased aircraft, many of which are managed by lessors based outside the Russian Federation, consultancy IBA said in a report examining which aircraft leasing companies were likely to be most at risk as a result of the conflict and sanctions.

“AerCap is likely to be the most exposed to hard-hitting economic sanctions, with 152 active, parked and stored aircraft across Russia and Ukraine,” IBA said.

If airlines fail, or are barred from complying with sanctions, lessors maintain contingent insurance policies, which could potentially cover repossession losses, Fitch said.

“Lessors also often have maintenance reserves and letters of credit associated with leases, which could reduce potential losses,” it said.

Aircraft lessors remain focused on active liquidity management, and issuers will have sufficient liquidity to withstand the potential near-term impact of lease terminations on collections, utilisations and cash flows and losses from unrecovered aircraft, the rating agency said.

Higher oil prices or a sustained oil shock, which can be a major risk for airlines, could in turn pressure aircraft lessors' performance metrics, but may also lead to increased demand for lessors' more fuel-efficient current generation aircraft and favourable order book positions with manufacturers, Fitch said.

Ten tax points to be aware of in 2026

1. Domestic VAT refund amendments: request your refund within five years

If a business does not apply for the refund on time, they lose their credit.

2. E-invoicing in the UAE

Businesses should continue preparing for the implementation of e-invoicing in the UAE, with 2026 a preparation and transition period ahead of phased mandatory adoption. 

3. More tax audits

Tax authorities are increasingly using data already available across multiple filings to identify audit risks. 

4. More beneficial VAT and excise tax penalty regime

Tax disputes are expected to become more frequent and more structured, with clearer administrative objection and appeal processes. The UAE has adopted a new penalty regime for VAT and excise disputes, which now mirrors the penalty regime for corporate tax.

5. Greater emphasis on statutory audit

There is a greater need for the accuracy of financial statements. The International Financial Reporting Standards standards need to be strictly adhered to and, as a result, the quality of the audits will need to increase.

6. Further transfer pricing enforcement

Transfer pricing enforcement, which refers to the practice of establishing prices for internal transactions between related entities, is expected to broaden in scope. The UAE will shortly open the possibility to negotiate advance pricing agreements, or essentially rulings for transfer pricing purposes. 

7. Limited time periods for audits

Recent amendments also introduce a default five-year limitation period for tax audits and assessments, subject to specific statutory exceptions. While the standard audit and assessment period is five years, this may be extended to up to 15 years in cases involving fraud or tax evasion. 

8. Pillar 2 implementation 

Many multinational groups will begin to feel the practical effect of the Domestic Minimum Top-Up Tax (DMTT), the UAE's implementation of the OECD’s global minimum tax under Pillar 2. While the rules apply for financial years starting on or after January 1, 2025, it is 2026 that marks the transition to an operational phase.

9. Reduced compliance obligations for imported goods and services

Businesses that apply the reverse-charge mechanism for VAT purposes in the UAE may benefit from reduced compliance obligations. 

10. Substance and CbC reporting focus

Tax authorities are expected to continue strengthening the enforcement of economic substance and Country-by-Country (CbC) reporting frameworks. In the UAE, these regimes are increasingly being used as risk-assessment tools, providing tax authorities with a comprehensive view of multinational groups’ global footprints and enabling them to assess whether profits are aligned with real economic activity. 

Contributed by Thomas Vanhee and Hend Rashwan, Aurifer

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Knowledge and Human Development Authority – 8005432 ext. 4 for Covid-19 queries

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Updated: March 07, 2022, 8:57 AM