Short & Sweet no. 7
Which offshore aircraft registrations can be used with Temporary Admissions when flying within the EU and UK?

• Chose the right registration to fly freely
• You might not want to use the Isle of Man (M) registration
• What are the pitfalls?
  

We are often asked which offshore aircraft registrations can be used with TA when an aircraft is being used both within the EU and the UK by an owner (including the UBO) and/or by an operator which resides outside the EU or the UK.

The customs aspect of flying within the EU
Any aircraft flying into the EU will operate under customs control using either the Temporary Admission procedure (TA) or full importation (FI). There are no other options. The TA procedure can only be used by EU outsiders where the aircraft is owned (including any UBOs), operated, registered, and based outside the EU, leaving EU insiders only one option: full importation. EU outsiders can, of course, choose to use full importation instead of TA if they find it beneficial. However, both options can be used commercially or privately if applied correctly

Most aircraft registrations can be used without problems
Most of the popular offshore aircraft registrations can be used with a few exceptions. Please have a look at the table below. Note that an EU aircraft registration can never be used with TA when flying within the EU.

* Cyprus, Ireland, and Malta are all inside the customs territory of the Union (EU)
** The Channel Islands are all outside the customs territory of the UK
*** The Isle of Man is inside the customs territory of the UK
**** San Marino is outside the customs territory of the Union (EU)

You might not want to use the Isle of Man (M) registration
It is perfectly fine to use the M-registration or an Isle of Man owner entity (including the UBO) regarding the EU regulation and when flying within the EU if the total setup meets the requirements for the Temporary Admission procedure. However, the same setup may create vast problems if flying to the UK. As we anticipate most aircraft will eventually fly to the UK or that every owner wants to at least have the possibility, we suggest not using an Isle of Man owner entity or the M-registration.

An Isle of Man connection means that the aircraft cannot use the TA procedure when flying to the UK, leaving a full UK importation as the only option. In many ways, the HMRC (British customs) has limited the access to aircraft importations unless the imposed VAT (20% of the aircraft’s value) is fully paid without the possibility of reclaiming. The risk is that the aircraft will be impounded by the HMRC.

How can we help?
If you have questions about the above, please do not hesitate to contact us.