I would categorise it as prudent expenditure of income.
Not if a huge chunk of income is generated by your airline in that bankrupt basket-case carrying southern europeans often on domestic routes, same airline that pretends to be based in what once was Saxonia (nowadays a Pakistani colony) but then we all know where they base most of their aircraft and crews.
If we then want to open a discussion about the concept of "permanent establishment" please be my guests....
The following investigation started well before the new EU regulation:
Ryanair accused of avoiding tax - The Irish Times - Tue, Oct 16, 2012