Transform has submitted its response to the Scottish Government’s consultation on the future of Air Departure Tax (ADT), highlighting the urgent need to address the aviation sector’s historic under-taxation and environmental impact.
Scotland now has full powers over aviation taxation on flights leaving Scottish airports, with the Air Departure Tax set to become operational in April 2027 and a new Highlands and Islands exemption under consultation.
What’s the problem with aviation tax?
Air travel remains the most carbon-intensive form of transport yet airlines pay no fuel duty and very little tax. This means the average car owner contributes more to the public purse than the biggest airlines.
This has kept ticket prices artificially cheap, particularly for domestic and short-haul flights, undermining efforts to reduce emissions and shift travellers to more sustainable modes like rail.
Scotland now has a unique opportunity to lead in rebalancing aviation taxation, using ADT both to raise revenue and to support climate action.
The Scottish Fiscal Commission estimates that Scotland’s share of APD revenues will reach £305 million in 2025-26 and could rise to £372 million by 2030-31.
In our response, we argue that fair taxation of aviation is not only an environmental necessity but a matter of social justice.
Currently, the richest 10% of UK travellers produce 7.5 times more flight emissions than lower-income groups, while half of Scots did not fly at all last year.
Supporting the transition to sustainable transport also requires promoting rail as a practical alternative. 2 in 5 flights from Scottish airports are domestic, often with efficient rail connections – and keeping domestic air travel artificially low undermines national climate targets.
What can the Scottish Government do?
In our response, we propose:
- Excluding private jets from any exemption and introducing a targeted ADT supplement to reduce their disproportionate environmental impact.
- Setting ADT rates at levels that contribute to an absolute reduction in aviation emissions, particularly for the most polluting forms of travel.
- Using ADT to support a modal shift from air to lower-carbon transport, particularly rail and coach, for domestic UK journeys.
- Prioritising price parity or cost advantages for rail over air on key routes such as Edinburgh/Glasgow to London.
- Commissioning independent research into the true economic impacts of aviation growth, including environmental costs and leakage of economic activity.
- Exploring the introduction of taxation on aviation fuel to address the sector’s longstanding under-taxation.
- Removing the exemption for flights from Inverness Airport to Lowland Scotland airports, to avoid incentivising air travel where rail or coach alternatives should be the norm.
- Reviewing and potentially removing the exemption for flights from Highlands and Islands airports to the rest of the UK, given the risk of undermining regional economic activity.
- Retaining exemptions only for the most remote Highlands and Islands airports where sustainable transport alternatives cannot provide competitive journey times.
- Maintaining the removal of exemptions for international flights from Highlands and Islands airports.

