Tour Operators Scheme - Applicable?

Hi.

Basic story, I've signed on a new client for the firm who is a starting travel agency. They have only just had their first quarter end and I'm doing the VAT for them including a pre-registration claim.

At the moment currently until they get their ABTA license they are simply selling travel flight packages which they buy from another agency and sell on. On their invoices they don't advertise the other agency, only themselves so the final consumer doesnt know where the package originally came from.

Now international VAT is not my field but from what I've researched the TOMS applies to this company and if so what does that mean for the first few quarters? From what it's saying the complex calculation with margins doesn't come into play until the first year is complete, so does that mean for the first 3 quarters all their travel sales are just zero rated, i.e. repayment claims?