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Full importation: what are the 10 typical errors and misunderstandings?

Added December 2018

Over the years we have received hundreds of different case descriptions on how aircraft operators have planned or been using full importation. They have been submitted in order for us to comment and possibly rectify the use. We have compiled the most typical errors and misunderstandings in the list below and included a short explanation and a link to access for further information.

Any aircraft flying into the EU must somehow come under EU customs control either using either the Temporary Admission regulation or full importation, there are no other options. So, if the aircraft is not already fully imported, the aircraft will automatically be considered as flying under the Temporary Admission regulation.

Please, have a look at it if you use full importation on a regular basis. The same list have also been published for users of Temporary Admission.

List of the 10 typical errors and misunderstandings:

The majority of the above-mentioned points are critical factors. Mistakes can be costly if the aircraft and the preconditions for the full importation are checked through a customs ramp check or an audit by VAT authorities.

Tax havens and the Paradise Papers
A few EU member states handle aircraft admission/importation differently. These states do not follow the EU standards or guidelines and this is often sanctioned by their local tax/customs authorities in order to offer a better business environment or to create local gateways for certain industries. These jurisdictions are known to bend the rules in favor of local companies often by only implementing a light version of any new regulation or by simply ignoring or delaying the required implementation. The Paradise Papers have highlighted some of these EU tax havens. These jurisdictions and related industries will without any doubt have the full attention of several national and EU authorities in the future. We will see many changes and audits of the regulation in the future thus no one should import an aircraft without a binding advance tax ruling.

Who can use full importation?
All private individuals and corporations regardless of nationality and residency can use full importation and act as the importer but some procedures require full payment of the VAT at 15-27% of the value of the aircraft. The full importation procedures are available in all 28 EU member states, but the practical handling and preconditions are often different. Full importation is mandatory for EU insiders which means that the aircraft is either owned/registered/operated/based and mainly used within the EU (just one criterion must be fulfilled). On the other hand, full importation is optional for EU outsiders, where the aircraft is both owned/registered/operated/based outside the EU (all criteria must be fulfilled). The only alternative for EU outsiders is to use the Temporary Admission regulation.

Check our online resources if you want to dig deeper into the above points!
OPMAS Short articles: gives a short insight in various topics
OPMAS Short stories: get the essence of the two importation alternatives in a short and quick way
OPMAS Reviews: present an overview and a deeper insight in various subjects
OPMAS Quick Guides: compare the different importation alternatives
OPMAS Video: use 3 minutes to get a quick introduction
OPMAS Surveys: in-depth analysis of specific topics

How can we help?
Please, ask OPMAS about the service we provide to support users of full importation. Our service covers much more than handling necessary customs paperwork. It is a turnkey solution for aircraft owners and operators who want to fly within the EU. Firstly, we analyze the owner/operator scenario to secure compliance with customs regulation and provide guidance for the correct use of full importation. Hereafter, we secure the specific set-up and take care of all supporting customs paperwork. Finally, we give specific instructions to crew and ops on how to fly within the EU including free support as long the aircraft is operated in the recommended way.

Let OPMAS help verify your usage. Please, send us an email or give us a call.